Supreme Court Dismisses NEET Re-Examination Plea Over Denial of Handkerchief
The case of Talluri Srikar (Minor) Through His Father Talluri Srikrishna vs. The Director, National Testing Agency & Ors. involved a legal challenge to the denial of a handkerchief in the NEET-UG 2024 examination hall, which the petitioner claimed adversely affected his performance. The Supreme Court, in its judgment dated September 13, 2024, upheld the Telangana High Court’s decision to reject the plea for a re-examination.
The case raises important questions about procedural fairness in competitive exams and the extent to which courts should intervene in individual grievances related to public examinations.
Background of the Case
The petitioner, Talluri Srikar, a NEET-UG 2024 candidate, suffers from a medical condition known as Hyperhidrosis, which causes excessive sweating of the palms and soles. He alleged that:
- He required a handkerchief to keep his palms dry during the examination.
- Despite being allowed to appear for NEET-UG 2024, he was not permitted to carry his handkerchief into the examination hall.
- The lack of a handkerchief caused significant discomfort, leading to difficulties in marking answers on the OMR sheet.
- Due to his inability to manage the sweat, he marked a wrong digit on the OMR sheet.
- He sought a re-examination, arguing that his condition was not accommodated.
The petitioner claimed that the National Testing Agency (NTA) had conducted a re-examination for 1563 candidates due to a delay in distributing question papers and sought the same relief.
Legal Proceedings
Representation to the NTA
- The petitioner initially submitted a representation to the National Testing Agency (NTA), seeking a re-examination.
- The NTA rejected his request on June 21, 2024, stating that his case did not warrant a re-examination.
Writ Petition Before the Telangana High Court
- The petitioner then filed a writ petition (W.P. No. 21897 of 2024) before the Telangana High Court.
- The High Court dismissed the petition on August 9, 2024, ruling that:
- The petitioner was given full examination time and did not suffer any time loss like the 1563 candidates who were granted a re-examination.
- Even if he was wrongly denied permission to carry a handkerchief, it would not have materially affected his performance.
- He could have wiped his palms on his clothes, making the denial of the handkerchief insignificant.
Appeal Before the Supreme Court
The petitioner challenged the High Court’s decision in the Supreme Court, arguing:
- The security personnel at the examination center negligently refused to allow him to carry a handkerchief, even though it was not a prohibited item.
- The inability to manage his Hyperhidrosis resulted in poor performance, affecting his college admission chances.
- Courts should recognize the impact of medical conditions on a candidate’s ability to perform well in exams.
Supreme Court’s Observations
The Supreme Court bench, comprising Chief Justice Dr. D.Y. Chandrachud and Justices J.B. Pardiwala and Manoj Misra, rejected the petitioner’s plea, making the following observations:
1. No Loss of Examination Time
- The Court ruled that the petitioner was given the full allotted time to complete the examination.
- The 1563 candidates who were granted a re-examination had suffered a loss of examination time due to administrative errors, which was not the case here.
2. Minimal Impact on Performance
- The Court noted that in a NEET-UG examination, where answers are marked by darkening circles on an OMR sheet, excessive sweating on the palms would not significantly hinder performance.
- The judgment cited that the petitioner could have wiped his palms on his clothes, which would have been an effective alternative.
3. Individual Grievances Should Not Delay Public Examinations
- The Court emphasized that courts must be cautious in interfering with competitive examination processes.
- Allowing individual grievances like this could delay the finalization of results and prejudice larger public interest.
Important Excerpts from the Judgment
“There is no case that allotted time for giving the examination was not provided to the petitioner at the examination center. Thus, the case of the petitioner is distinguishable from those 1563 candidates for whom re-examination was conducted.”
“Even if it is assumed that the petitioner was wrongly denied permission to carry a handkerchief, the same would not have materially affected his performance in the examination as sweat on palms could easily be wiped off on the clothes worn by a person.”
“Courts must be circumspect in entertaining an individual grievance relating to a public examination as it delays finalization of results, thereby seriously prejudicing larger public interest.”
Final Judgment
The Supreme Court ruled:
- The petition lacked merit and was dismissed.
- The Telangana High Court’s order was upheld.
- The pending applications in connection with the case were disposed of.
Implications of the Judgment
This ruling has several important legal and practical implications:
- Limits on Re-Examinations: The decision ensures that requests for re-examinations are only granted in cases of significant procedural lapses, such as lost exam time.
- Standardization in Exam Conduct: The ruling affirms that minor inconveniences in exam conditions do not justify judicial intervention.
- Protection of Competitive Exams: The judgment underscores that individual grievances should not disrupt large-scale competitive examinations.
The Supreme Court’s ruling reinforces the principle that courts should not interfere lightly in matters related to public examinations, ensuring the stability of admission processes while safeguarding fairness in assessment.
Petitioner Name: Talluri Srikar (Minor) Through His Father Talluri Srikrishna.Respondent Name: The Director, National Testing Agency & Ors..Judgment By: Justice D.Y. Chandrachud, Justice J.B. Pardiwala, Justice Manoj Misra.Place Of Incident: Telangana, India.Judgment Date: 13-09-2024.
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