The Lahore High Court has ruled that parties cannot file an intra-court appeal in public procurement disputes when the Punjab Public Procurement Regulatory Authority Rules provide a complete legal review process. A division bench comprising Justice Chaudhry Sultan Mahmood and Justice Malik Muhammad Owais Khalid issued the decision while hearing an appeal filed by a private company.

The dispute began after the Punjab Health Department invited electronic bids for the purchase of medical equipment, surgical disposables, implants and sutures for the 2025-26 financial year. During the technical evaluation, the Technical Evaluation Committee declared the bids of several companies technically non-responsive, and the Grievance Redressal Committee later upheld that decision.

The affected companies subsequently challenged the decision before the Managing Director of the Punjab Public Procurement Regulatory Authority under Rule 67-A of the Punjab Procurement Rules 2014. After examining the case, the managing director reversed the earlier findings, declared the companies technically qualified and instructed authorities to continue the procurement process in accordance with the law.

A constitutional petition against the managing director’s decision was later dismissed by a single bench of the Lahore High Court, after which the petitioner filed an intra-court appeal. The division bench, however, held that the review forums established under Rules 67 and 67-A have full statutory authority to examine, modify or overturn procurement decisions.

The court further observed that the managing director’s ruling is part of the statutory review mechanism rather than an original order, making Section 3(2) of the Law Reforms Ordinance, 1972 applicable. Relying on Supreme Court judgments, the bench concluded that where a special law provides a complete legal remedy, an intra-court appeal cannot proceed unless the legislation specifically allows it, and therefore dismissed the appeal as non-maintainable.