Normalization in Police Recruitment: Supreme Court Upholds Equi-Percentile Method

The case of State of Uttar Pradesh & Ors. v. Atul Kumar Dwivedi & Ors. dealt with the issue of normalization in the recruitment process for the post of Sub-Inspector, Platoon Commander, and Fire Officer in the Uttar Pradesh Police. The Supreme Court examined whether the normalization process used by the Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB) was legally valid and whether it could be applied at the eligibility stage.

The controversy arose when candidates who had secured 50% raw marks in the written examination were disqualified because normalization reduced their scores below the qualifying threshold. The petitioners argued that their eligibility should be determined based on raw marks rather than normalized scores.

Background of the Case

In 2016, the Uttar Pradesh Police Recruitment and Promotion Board issued an advertisement for the recruitment of 3,307 posts, including Sub-Inspectors, Platoon Commanders, and Fire Officers. The written examination was conducted online in multiple shifts, leading to concerns about the varying difficulty levels of the question papers.

To ensure fairness in the evaluation process, the Board adopted the Standardized Equi-Percentile Method for normalization. Under this method, the raw marks of candidates from different shifts were adjusted to a common scale, ensuring that no candidate was disadvantaged due to variations in question paper difficulty.

However, the issue arose when some candidates who had secured 50% raw marks were disqualified after normalization, as their normalized scores fell below the qualifying threshold. This led to a legal challenge before the High Court.

Arguments by the Petitioners

The petitioners, who were disqualified due to normalization, argued:

Rule 15(b) of the Uttar Pradesh Sub-Inspector and Inspector (Civil Police) Service Rules, 2015, mandated that candidates must obtain 50% marks in each subject to qualify. This rule made no reference to normalization.
The Board’s decision to apply normalization to determine eligibility violated the recruitment rules.
Normalization should only be applied at the merit list stage and not at the eligibility stage.
The use of normalization deprived them of their right to be considered for recruitment despite securing the required 50% raw marks.

Arguments by the Respondents

The State of Uttar Pradesh and the Recruitment Board defended their decision, stating:

The examination was conducted in multiple shifts, and variations in question paper difficulty could lead to unfair advantages or disadvantages for some candidates.
Normalization ensured that all candidates were evaluated on a level playing field.
The normalization process was notified in advance and applied uniformly to all candidates.
If normalization were applied only at the merit list stage, candidates who secured less than 50% raw marks but more than 50% normalized marks would be unfairly excluded.

Key Observations by the Supreme Court

The Supreme Court examined the legality of applying normalization at the eligibility stage. The key observations included:

1. Rule 15(b) and the Definition of ‘Marks’

The Court noted that Rule 15(b) of the recruitment rules required candidates to obtain 50% marks in each subject to qualify. However, it did not specify whether these marks should be raw or normalized.

“The expression ‘marks’ in Rule 15 must be given a uniform interpretation throughout the recruitment process. If normalization is applied at the merit list stage, it must also apply at the eligibility stage.”

2. Fairness and Justification of Normalization

The Court acknowledged that the use of different question papers across multiple shifts could lead to significant variations in scores. It cited similar practices in national-level examinations, such as the Joint Entrance Examination (JEE) and Graduate Aptitude Test in Engineering (GATE), where normalization is used to ensure fairness.

“The purpose of normalization is to eliminate any advantage or disadvantage caused by differences in question paper difficulty. It ensures a uniform assessment process.”

3. Validity of Normalization at the Eligibility Stage

The Court rejected the argument that normalization should only be applied while preparing the merit list. It held that the process of normalization must be applied consistently across all stages of recruitment.

“If normalization were applied only at the merit list stage, candidates who secured less than 50% raw marks but more than 50% normalized marks would be unfairly excluded. Thus, normalization must apply at the eligibility stage as well.”

4. Pre-Notified Examination Rules

The Court observed that the normalization process was included in the recruitment notification and was applied uniformly to all candidates.

“The recruitment notification clearly stated that normalization would be used. Candidates participated in the examination with full knowledge of this process.”

5. No Violation of Fundamental Rights

The Court rejected the argument that normalization violated Articles 14 and 16 of the Constitution (Right to Equality and Equal Opportunity in Employment). It held that normalization was a scientifically recognized method for fair evaluation and was applied in a non-discriminatory manner.

“The application of normalization does not violate fundamental rights as it is a fair and rational method to ensure equal opportunity for all candidates.”

Final Judgment

The Supreme Court upheld the validity of normalization at the eligibility stage and dismissed the petitioners’ claims. The key takeaways from the judgment are:

The Recruitment Board had the authority to apply normalization at both the eligibility and merit list stages.
The use of the Standardized Equi-Percentile Method ensured fairness in the selection process.
The recruitment results declared on February 28, 2019, were to remain unchanged.
The State of Uttar Pradesh was advised to consider granting age relaxation or additional weightage to disqualified candidates in future recruitments.

This judgment affirms the principle that recruitment authorities can adopt scientifically valid methods like normalization to ensure fair selection, provided such methods are pre-declared and uniformly applied.

Petitioner Name: State of Uttar Pradesh & Ors..
Respondent Name: Atul Kumar Dwivedi & Ors..
Judgment By: Justice Uday Umesh Lalit, Justice Vineet Saran.
Place Of Incident: Uttar Pradesh.
Judgment Date: 07-01-2022.

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