Wymiar konsekwencji

Przepisy pzp regulują kwestię uchylania się od zawarcia umowy przez wykonawcę. Wiążą z tym uprawnienia zamawiającego (np. do wybrania kolejnej oferty z rankingu) oraz sankcje dla wykonawcy w postaci utraty wniesionego wadium. W art. 93 ust. 4 pzp zawarte są uprawnienia wykonawcy w sytuacji unieważnienia postępowania z przyczyn leżących po stronie zamawiającego. Ale co w przypadku gdy to zamawiający uchyla sie  od podpisania umowy ?

Nie można tu wyprowadzić prostej analogii z art. 93 ust. 4 pzp i zastosować takiego samego rozwiązania w przypadku uchylenia się zamawiającego od podpisania umowy w przypadku rozstrzygnięcia postępowania. Gdyby taka była intencja ustawodawcy, przepis traktowałaby oprócz unieważnienia postępowania, także o odmowie podpisania umowy przez zamawiającego.

Chociaż uchylanie się zamawiającego od podpisania umowy z wykonawcą wybranym w postępowaniu o udzielenie zamówienia publicznego przeczy celowi zamówienia publicznego, którym jest zawarcie umowy przepisy pzp w ogóle nie odnoszą się do takiej sytuacji 😉

W sytuacji uchylenia się zamawiającego od podpisania umowy w sprawie zamówienia publicznego nie przysługuje także odwołanie do Krajowej Izby Odwoławczej. Świadczy o tym treść art. 192 ust. 6 pzp, który traktuje, że skład orzekający Krajowej Izby Odwoławczej nie może nakazać zawarcia umowy. Roszczenie o zawarcie umowy a contrario nie mogłoby być więc podstawą wniesienia odwołania do KIO. Przepisy ustawy pzp nie przewidują także nakładania kar umownych na zamawiającego za nie podpisanie przez niego umowy z wybranym w postępowaniu wykonawcą. Nie podpisanie umowy z wybranym w postępowaniu wykonawcą samo w sobie nie stanowi także naruszenia dyscypliny finansów publicznych.

W tej sytuacji zastosowanie znajdują jednak przepisy Kodeksu cywilnego.

Zgodnie z orzecznictwem Krajowej Izby Odwoławczej wszczęcie postępowania o udzielenie zamówienia publicznego powinno być traktowane w kategoriach swego rodzaju przyrzeczenia publicznego, w którym Zamawiający zobowiązuje się udzielić zamówienia publicznego konkretnemu, wybranemu w postępowaniu podmiotowi, przy wypełnieniu określonych wymogów i przesłanek, których to przyrzeczenie publiczne również dotyczy. Jeśli wykonawca złożył ofertę najkorzystniejszą zgodną z warunkami i wymaganiami postępowania oraz specyfikacją ma prawo oczekiwać, że zostanie mu udzielone zamówienie (zob. wyrok KIO z 29.05.2013 r.; KIO 1086/13, wyrok KIO z 11.01.2011 r.; KIO 2789/10).

Co prawda definicji przyrzeczenia publicznego z art. 919 § 1 kc sensu stricte odpowiada konkurs, jednakże wykonawca, którego oferta została wybrana w drodze postępowania o udzielenie zamówienia publicznego także może domagać się zawarcia umowy na drodze postępowania cywilnego. W przypadku wydania wyroku przez sąd cywilny wyrok taki zastępuje umowę. W Polsce zapadł już wyrok o zawarcie umowy w sprawie zamówienia publicznego, zastępujący w całości umowę. W wyroku z 16.07.2009 r. Sąd Okręgowy w Warszawie (sygn. akt: XVI GC 682/08) stwierdził istnienie możliwości zawarcia umowy na warunkach określonych w specyfikacji istotnych warunków zamówienia i w ofercie wykonawcy. Wynika z niego potwierdzenie zasady, że można dochodzić zawarcia umowy w sprawie zamówienia publicznego, gdy zamawiający uchyla się od jej zawarcia. Wykonawcy na gruncie przepisów k.c. przysługuje także roszczenie odszkodowawcze wobec zamawiającego.

Konsekwencje w przypadku odmówienia podpisania umowy z wykonawcą mogą być dla zamawiającego dość dotkliwe.

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  556. Between me and my husband we’ve owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I’ve settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.

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  558. If you’re still on the fence: grab your favorite earphones, head down to a Best Buy and ask to plug them into a Zune then an iPod and see which one sounds better to you, and which interface makes you smile more. Then you’ll know which is right for you.

  559. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It’s very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.

  560. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It’s very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.

  561. Hands down, Apple’s app store wins by a mile. It’s a huge selection of all sorts of apps vs a rather sad selection of a handful for Zune. Microsoft has plans, especially in the realm of games, but I’m not sure I’d want to bet on the future if this aspect is important to you. The iPod is a much better choice in that case.

  562. I’ll gear this review to 2 types of people: current Zune owners who are considering an upgrade, and people trying to decide between a Zune and an iPod. (There are other players worth considering out there, like the Sony Walkman X, but I hope this gives you enough info to make an informed decision of the Zune vs players other than the iPod line as well.)

  563. The Zune concentrates on being a Portable Media Player. Not a web browser. Not a game machine. Maybe in the future it’ll do even better in those areas, but for now it’s a fantastic way to organize and listen to your music and videos, and is without peer in that regard. The iPod’s strengths are its web browsing and apps. If those sound more compelling, perhaps it is your best choice.

  564. The new Zune browser is surprisingly good, but not as good as the iPod’s. It works well, but isn’t as fast as Safari, and has a clunkier interface. If you occasionally plan on using the web browser that’s not an issue, but if you’re planning to browse the web alot from your PMP then the iPod’s larger screen and better browser may be important.

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  568. Between me and my husband we’ve owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I’ve settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.

  569. Apple now has Rhapsody as an app, which is a great start, but it is currently hampered by the inability to store locally on your iPod, and has a dismal 64kbps bit rate. If this changes, then it will somewhat negate this advantage for the Zune, but the 10 songs per month will still be a big plus in Zune Pass’ favor.

  570. This is getting a bit more subjective, but I much prefer the Zune Marketplace. The interface is colorful, has more flair, and some cool features like ‚Mixview’ that let you quickly see related albums, songs, or other users related to what you’re listening to. Clicking on one of those will center on that item, and another set of „neighbors” will come into view, allowing you to navigate around exploring by similar artists, songs, or users. Speaking of users, the Zune „Social” is also great fun, letting you find others with shared tastes and becoming friends with them. You then can listen to a playlist created based on an amalgamation of what all your friends are listening to, which is also enjoyable. Those concerned with privacy will be relieved to know you can prevent the public from seeing your personal listening habits if you so choose.

  571. The Zune concentrates on being a Portable Media Player. Not a web browser. Not a game machine. Maybe in the future it’ll do even better in those areas, but for now it’s a fantastic way to organize and listen to your music and videos, and is without peer in that regard. The iPod’s strengths are its web browsing and apps. If those sound more compelling, perhaps it is your best choice.

  572. The Zune concentrates on being a Portable Media Player. Not a web browser. Not a game machine. Maybe in the future it’ll do even better in those areas, but for now it’s a fantastic way to organize and listen to your music and videos, and is without peer in that regard. The iPod’s strengths are its web browsing and apps. If those sound more compelling, perhaps it is your best choice.

  573. The Zune concentrates on being a Portable Media Player. Not a web browser. Not a game machine. Maybe in the future it’ll do even better in those areas, but for now it’s a fantastic way to organize and listen to your music and videos, and is without peer in that regard. The iPod’s strengths are its web browsing and apps. If those sound more compelling, perhaps it is your best choice.

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  584. The Zune concentrates on being a Portable Media Player. Not a web browser. Not a game machine. Maybe in the future it’ll do even better in those areas, but for now it’s a fantastic way to organize and listen to your music and videos, and is without peer in that regard. The iPod’s strengths are its web browsing and apps. If those sound more compelling, perhaps it is your best choice.

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  587. Hands down, Apple’s app store wins by a mile. It’s a huge selection of all sorts of apps vs a rather sad selection of a handful for Zune. Microsoft has plans, especially in the realm of games, but I’m not sure I’d want to bet on the future if this aspect is important to you. The iPod is a much better choice in that case.

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  590. The new Zune browser is surprisingly good, but not as good as the iPod’s. It works well, but isn’t as fast as Safari, and has a clunkier interface. If you occasionally plan on using the web browser that’s not an issue, but if you’re planning to browse the web alot from your PMP then the iPod’s larger screen and better browser may be important.

  591. Hands down, Apple’s app store wins by a mile. It’s a huge selection of all sorts of apps vs a rather sad selection of a handful for Zune. Microsoft has plans, especially in the realm of games, but I’m not sure I’d want to bet on the future if this aspect is important to you. The iPod is a much better choice in that case.

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