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In a recent judicial pronouncement in Shreya Patil Agro Producer Company Ltd., Through its Director, Devidas Babasaheb Dhupe, Jalna v/s The State of Maharashtra, Through its Secretary, Agricultural & Marketing Department, Mumbai & Others, a court has ruled in favor of a petitioner challenging an erroneous decision by state authorities concerning an agricultural grant. The petition, filed against the Assistant Project Director of the Nanaji Deshmukh Krushi Sanjeevani Prakalp (NDKSP), questioned the validity of an order that had canceled the petitioner’s Start Work Order based on allegations of submitting false information.

Background:

The petitioner had applied for benefits under the NDKSP on August 18, 2022. This scheme provides financial aid for purchasing agricultural equipment and constructing sheds. Following the application, the petitioner acquired agricultural machinery worth ?19,67,000 and received a pre-sanction letter on July 19, 2022, along with a Start Work Order dated September 25, 2022. However, a dispute arose regarding the incorporation date of the petitioner’s company. The company was officially incorporated on February 2, 2022, as indicated by the certificate issued by the Assistant Registrar of Companies. Despite this, an error occurred during the application process where the incorporation date was incorrectly entered as May 11, 2022, rather than February 2, 2022.

The Dispute:

The crux of the issue was whether this date discrepancy constituted fraudulent behavior or was merely a clerical error. The Assistant Project Director of the NDKSP had canceled the Start Work Order, accusing the petitioner of submitting false documents and misleading information. This decision was based on the incorrect date provided in the online application form. The petitioner contested this decision, arguing that the incorporation certificate, which was correctly dated, proved the authenticity of their company’s establishment. The mistake in the application form did not reflect fraudulent intent but rather an honest error in data entry.

Court’s Findings:

Upon review, the court found that the impugned order of January 31, 2024, which accused the petitioner of submitting false information, was unsustainable. The court noted that there was no evidence of any false documents submitted on the portal, and the incorporation certificate provided was valid and accurate. The misreported date in the application form was deemed a minor clerical error rather than evidence of fraud. The court highlighted that the Start Work Order was issued based on the valid incorporation certificate and that any discrepancies in the application form did not alter the legitimacy of the petitioner’s company or their eligibility for the grant.

Ruling:

The court quashed the impugned order and upheld the pre-sanction letter and Start Work Order. It directed the relevant authorities to correct the online application form to reflect the accurate date of incorporation and proceed with the grant disbursement in accordance with the project guidelines. In conclusion, the court’s ruling underscores the importance of distinguishing between genuine fraud and clerical errors. The decision reiterates that procedural mistakes should not unduly penalize applicants who have otherwise complied with the requirements of the grant scheme.

COMPANIES ACT, 2013