Haryana Civil Judge (Junior Division) Examination 2017: Pranav Verma & Ors. vs The Registrar General of the High Court of Punjab and Haryana

This case revolves around the Haryana Civil Judge (Junior Division) Examination 2017, wherein more than 90 candidates, including the petitioners, challenged the entire selection process and evaluation method adopted for the Main Examination. The petitioners sought to quash the result declared on 11.04.2019 and requested that their papers be re-evaluated by an Independent Expert Committee. The case also raised the issue of whether an Independent Judicial Service Commission should be constituted for conducting judicial exams in Haryana.

Factual Background:

In 2016, a notification was issued for recruitment to 109 posts of Civil Judge (Junior Division) in Haryana. However, the original examination was scrapped due to a question paper leak, leading to the re-notification of 107 posts in 2018.
The examination was conducted in three stages: Preliminary Examination, Main Examination, and Viva Voce. The results of the Main Exam, conducted from 15.03.2019 to 17.03.2019, were declared on 11.04.2019. Only 9 candidates were found eligible for the Viva Voce, which the petitioners contested.
The petitioners contended that the selection process was unjust, arbitrary, and violative of Article 14 of the Constitution, particularly due to the lack of clear marking criteria and transparency in the evaluation process.

Petitioner and Respondent Arguments:

Petitioner (Pranav Verma & Others): The petitioners argued that the evaluation lacked a clear marking criterion and that candidates were unfairly excluded due to stringent and inconsistent marking in the Civil Law-I paper. They further claimed that no model answer key or grading system was available for the evaluation, and suggested that grace marks or moderation techniques should be applied to ensure fairness in the results.

Respondent (The Registrar General of the High Court of Punjab and Haryana): The respondents, representing the Punjab and Haryana High Court, countered by stating that the selection process was conducted fairly and impartially, with adequate security measures in place. They opposed the petitioners’ claims for grace marks and moderation, asserting that the evaluation was done according to established procedures and that the results should stand as declared.

Important Judge Arguments:

Justice S. A. Bobde: Justice Bobde, in delivering the judgment, noted the petitioners’ concerns regarding the evaluation process but emphasized that the issue of marking was not a matter of personal discretion by the examiners. He pointed out that while strict marking in the Civil Law-I paper may have impacted the number of candidates qualifying, this did not constitute an arbitrary practice. However, he also acknowledged the need for moderation to address the discrepancy in the number of candidates qualifying for the Viva Voce.

Justice B.R. Gavai: Justice Gavai agreed with the concerns raised regarding the marking standards and supported the suggestion to introduce moderation in the marking system. He suggested awarding grace marks in both Civil Law-I and Civil Law-II papers to ensure that deserving candidates were not unfairly excluded from the Viva Voce stage.

Legal Provisions and Case Law:

Article 14 of the Constitution: The petitioners argued that the entire process violated the right to equality under Article 14, as it was neither fair nor transparent.
Precedent: Sanjay Singh & Anr. v. U.P. Public Service Commission (2007): The Court discussed the importance of uniformity in marking, particularly in judicial service examinations, and the necessity for moderation to address examiner variability.
Precedent: CPIL v. Registrar General of the High Court of Delhi (2017): The Court referred to this case to emphasize the importance of transparency and uniformity in the examination process, including the use of model answer keys and clear marking criteria.

Justice Sikri’s Report:

Justice Sikri was tasked with evaluating the grading and selection process. His report identified strict marking in the Civil Law-I paper as a significant issue. He suggested three alternatives for awarding grace marks to ensure more candidates qualified for the Viva Voce:

Alternative I: Awarding 20 grace marks in Civil Law-I to enable 28 additional candidates to qualify.
Alternative II: Awarding 20 grace marks in Civil Law-I and 10 grace marks in Civil Law-II to allow 60 candidates to qualify.
Alternative III: Awarding 35 grace marks in total to allow 74 candidates to qualify.

Final Judgment:

The Supreme Court ruled in favor of the petitioners by directing the Punjab and Haryana High Court to award grace marks in both Civil Law-I and Civil Law-II papers. Alternative II, which awarded 20 grace marks in Civil Law-I and 10 in Civil Law-II, was adopted. The Court ordered the preparation of fresh results within two weeks and the completion of the selection process within four weeks thereafter. The Court also emphasized the need for timely completion of future examination cycles.

Conclusion:

The judgment reflects the Court’s commitment to ensuring fairness and transparency in judicial recruitment examinations. By adopting moderation techniques, the Court sought to provide candidates with a fair chance to qualify for the next stage, while upholding the integrity of the examination process. This decision serves as a precedent for future recruitment processes in judicial services.

Petitioner Name: Pranav Verma & Others.
Respondent Name: The Registrar General of the High Court of Punjab and Haryana.
Judgment By: Justice S. A. Bobde, Justice B.R. Gavai, Justice Surya Kant.
Place Of Incident: Punjab and Haryana.
Judgment Date: 13-12-2019.

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