Supreme Court Orders Re-evaluation in Jharkhand Sub-Inspector Recruitment Dispute

The Supreme Court of India recently delivered a significant ruling in Sachit Kumar Singh & Ors. vs. State of Jharkhand & Ors., addressing a dispute regarding the recruitment process for the post of Sub-Inspector of Police in Jharkhand. The case involved candidates challenging the correctness of answers in the competitive examination conducted by the Jharkhand Staff Selection Commission (JSSC) in 2017.

Background of the Case

The Jharkhand Staff Selection Commission (JSSC) issued Advertisement No. 09/2017, inviting applications for 1,544 posts of Sub-Inspector of Police through a limited competitive examination. The recruitment process attracted 3,350 applicants, out of which 3,219 candidates appeared for the examination.

To qualify for the written examination, candidates were required to secure:

45% marks in both Paper-2 and Paper-3.
50% aggregate marks overall.
SC/ST candidates were given a relaxation of 5% in minimum qualifying marks.

After the evaluation, only 663 candidates managed to meet the qualifying criteria, while 399 candidates were declared successful. Following physical and medical tests, 396 candidates were finally appointed.

Petitioners’ Grievance

The original writ petitioners, who fell short of the required qualifying marks by just one or two marks, made representations on December 1, 2017, and subsequently on January 6 and January 8, 2018. They raised objections against the correctness of nine questions in the examination, arguing that:

The official answer key contained incorrect answers.
Some questions were out of the prescribed syllabus.
The evaluation process lacked an expert review of disputed questions.

Proceedings in the High Court

The petitioners filed writ petitions before the Jharkhand High Court, seeking either:

Re-evaluation of their answer sheets.
Striking down the disputed questions.
Obtaining an expert’s opinion on the correctness of the answers.

The JSSC opposed the petitions, arguing:

The petitioners did not raise their objections within the prescribed period of December 1 to December 8, 2017.
Even if the disputed questions were found to be incorrect, the error affected all candidates equally, and no prejudice was caused.

High Court’s Decision

The High Court dismissed the petitions, ruling that:

The objections were not filed within the stipulated period.
The disputed questions affected all candidates, meaning no specific disadvantage was caused to the petitioners.
Even if additional marks were granted to the petitioners, they would have to be granted to all other candidates, maintaining the existing merit list.

Arguments Before the Supreme Court

Arguments by the Petitioners

Senior Advocate Gopal Sankaranarayanan, appearing for the petitioners, argued:

The petitioners had indeed raised objections within the prescribed time, but the JSSC ignored them.
The High Court wrongly concluded that adding marks for the disputed questions would not impact the petitioners’ eligibility.
Several posts from the recruitment drive remained vacant, which could have accommodated the petitioners if the disputed questions were addressed properly.

Arguments by the Respondents

The Jharkhand Staff Selection Commission and the State defended their actions, arguing:

The objections were raised after the deadline and could not be entertained.
Since all candidates answered the same questions, no individual candidate suffered unfairly.
Adding marks for the disputed questions would mean granting marks to all candidates, leaving the merit order unchanged.

Supreme Court’s Observations

The Supreme Court bench, comprising Justices M.R. Shah and C.T. Ravikumar, made the following key observations:

“The High Court took a too technical view by rejecting the petitioners’ claims solely on the basis of late objection filing.”
“Even if the objections were raised late, they were filed before the final results were declared on January 9, 2018.”
“If there were errors in the answer key, they should have been verified by an expert before finalizing the selection process.”
“If the expert review found discrepancies in the answer key, awarding additional marks could make the petitioners eligible and impact the selection process.”

Final Judgment

The Supreme Court ruled:

The High Court’s decision to dismiss the objections on technical grounds was incorrect.
The matter was remanded back to the Jharkhand High Court for fresh consideration.
The High Court must obtain an expert’s opinion on the disputed questions before making a final decision.
The process should be completed within three months to avoid further delays in recruitment.

Implications of the Judgment

The Supreme Court’s decision has major implications for recruitment processes and the legal standards for competitive examinations:

Objection Deadlines Should Not Be Rigidly Applied: The ruling clarifies that late objections can be entertained if they are filed before result declaration.
Expert Review in Examinations: Courts should seek expert opinions when answer key discrepancies are alleged.
Impact on Future Recruitment Cases: The decision sets a precedent for candidates challenging flawed evaluation processes.

Conclusion

The Supreme Court’s ruling in Sachit Kumar Singh & Ors. vs. State of Jharkhand & Ors. ensures fairness in recruitment examinations. By remanding the matter to the High Court for expert evaluation, the Court has reinforced the principle that selection processes must be transparent, merit-based, and free of technical irregularities.

Petitioner Name: Sachit Kumar Singh & Ors..
Respondent Name: State of Jharkhand & Ors..
Judgment By: Justice M.R. Shah, Justice C.T. Ravikumar.
Place Of Incident: Jharkhand.
Judgment Date: 28-04-2023.

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