Judicial Review in Exam Evaluations: Supreme Court Ruling on U.P. Public Service Commission Dispute

The Supreme Court of India delivered an important judgment in the case of U.P. Public Service Commission (UPPSC) vs. Rahul Singh & Ors., concerning judicial review in examination evaluations. The case involved the UPPSC’s preliminary examination for the Uttar Pradesh Upper Subordinate Services, where discrepancies in answer keys led to legal challenges by candidates.

The judgment reaffirmed the principle that courts should exercise restraint in interfering with expert evaluations in academic matters unless there is a glaring mistake that is demonstrably incorrect. This decision provides clarity on the limited scope of judicial review in competitive examinations.

Background of the Case

The UPPSC issued an advertisement on 22 February 2017 for recruitment in the Uttar Pradesh Upper Subordinate Services. The selection process involved three stages:

• Preliminary examination
• Main examination
• Interview

The preliminary examination consisted of two papers: General Studies-I and General Studies-II. The dispute pertained to the General Studies-I paper, which carried 200 marks and comprised 150 objective-type questions with multiple-choice answers.

After the examination, UPPSC published its official answer key, which sparked objections from candidates who alleged that certain answers were incorrect or had multiple correct responses. Initially, UPPSC constituted two expert committees to verify the key answers. Later, in response to objections, a 26-member expert committee was formed to further examine the disputed questions.

Following this review, UPPSC made the following corrections:

• Deleted 5 questions.
• Revised answers for 2 questions.

The final results were then declared based on 145 questions instead of the original 150.

Arguments of the Petitioners (Rahul Singh & Others)

The petitioners challenged UPPSC’s evaluation before the Allahabad High Court, raising objections to 14 questions. Their arguments were:

• Several key answers were demonstrably incorrect and required correction.
• Some questions had more than one correct answer, making it unfair to accept only one as correct.
• The 26-member expert committee failed to properly evaluate the objections.
• UPPSC should have further reviewed the disputed questions before finalizing the results.

Arguments of the Respondents (UPPSC)

UPPSC defended its evaluation process, arguing:

• The answer keys had already been moderated by multiple expert committees.
• The 26-member committee reviewed 962 objections and made appropriate corrections.
• Court intervention in academic matters should be minimal and limited to cases of manifest errors.
• Judicial review should not override the decision of subject matter experts.

High Court’s Decision

The Allahabad High Court examined the disputed questions and upheld UPPSC’s answers for 11 of them. However, it ruled against UPPSC on three questions:

• One question should be deleted.
• Another question had two correct answers.
• One more question’s answer key was found to be incorrect and required correction.

UPPSC appealed the High Court’s decision before the Supreme Court, arguing that courts should not interfere with expert evaluations unless the errors are clearly demonstrable and require no inferential reasoning.

Supreme Court’s Observations

The Supreme Court analyzed past rulings on judicial review in competitive examinations and emphasized:

• “Courts should not interfere in academic matters unless the answer key is proved to be wrong beyond any doubt.”
• “Judges are not subject matter experts and should rely on expert committees to determine the correctness of answers.”
• “The burden of proof is on the candidate to establish that a key answer is patently incorrect and not just debatable.”
• “Judicial intervention should be exercised only in rare or exceptional cases where an error is so obvious that no reasonable expert can dispute it.”

The Supreme Court also referenced its past decisions:

• Kanpur University vs. Samir Gupta (1983): Answer keys should be presumed correct unless clearly proven otherwise.
• Ran Vijay Singh vs. State of U.P. (2018): Courts should not conduct re-evaluation unless there is a glaring mistake.

Final Judgment

The Supreme Court set aside the Allahabad High Court’s ruling and reinstated UPPSC’s original decision. It held:

“The High Court overstepped its jurisdiction by overruling the expert committee’s decision. Judicial review in matters of competitive exams is limited, and courts should defer to subject matter experts unless a mistake is clearly established.”

With this ruling, the Supreme Court reinforced that competitive exam evaluations should be handled by experts and not be subjected to judicial interference unless there is a demonstrable, indisputable error.

Petitioner Name: U.P. Public Service Commission.
Respondent Name: Rahul Singh & Ors..
Judgment By: Justice Uday Umesh Lalit, Justice Deepak Gupta.
Place Of Incident: Uttar Pradesh.
Judgment Date: 14-06-2018.

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