New Delhi: In a significant ruling for civil services aspirants, the Delhi High Court has held that courts can interfere with examination answer keys if the suggested answers are “patently incorrect.” The Court made the observation while hearing a petition filed by a candidate who appeared in the UPSC Indian Forest Service (IFS) Examination, 2022, and directed the Central Administrative Tribunal (CAT) to reconsider the matter afresh. The Court clarified that while judicial interference in academic matters is generally limited, there is no absolute bar on examining answer keys where the official answers are demonstrably wrong.
Delhi High Court’s Significant Observation
A Division Bench comprising Justice C. Hari Shankar and Justice Om Prakash Shukla observed that courts are not completely barred from examining the correctness of official answer keys issued by examination authorities.
The Bench held – “It is settled law that there is no absolute bar on a Court examining such a contention and that, if the suggested answers as per the suggested answer keys are patently incorrect, the Court can interfere.“
The Court, however, clarified that such intervention would only be justified in exceptional cases where the answer is clearly and demonstrably incorrect.
Background of the Case
The case arose from a petition filed by a candidate belonging to the Other Backward Classes (OBC) Non-Creamy Layer, who appeared in the UPSC Indian Forest Service (IFS) Examination, 2022.
The candidate failed to qualify for the examination and subsequently approached the Central Administrative Tribunal (CAT) challenging the correctness of two answers in the official answer key for General Studies Paper-I.
According to the petitioner:
- Question No. 88: The official answer key identified Option (d) as the correct answer, whereas the petitioner argued that Option (c) was the correct answer.
- Question No. 96: The official answer key identified Option (d) as the correct answer, while the petitioner contended that Option (b) was the correct answer.
The candidate maintained that the incorrect answer key adversely affected his result in the examination.
Tribunal Had Dismissed the Petition
The Central Administrative Tribunal had earlier dismissed the petition by relying on one of its previous decisions.
However, the High Court noted that the Tribunal did not actually examine whether the disputed answers were correct or incorrect.
Instead, it rejected the plea without considering the substantive issue raised by the petitioner.
Candidate Was Not Seeking Re-evaluation
A key aspect highlighted by the High Court was that the petitioner had not sought re-evaluation of his answer sheet.
Instead, he had challenged the correctness of the official model answer key released by UPSC.
The Court observed that the Tribunal had erred in treating the matter as one involving re-evaluation rather than examining whether the official answer key itself contained demonstrably incorrect answers.
Court Relies on Earlier Judgment
While deciding the matter, the Bench relied on its earlier decision in Staff Selection Commission v. Shubham Pal & Others.
Referring to that judgment, the Court reiterated that there is no absolute prohibition on judicial scrutiny of official answer keys.
The Bench observed, “Of course, where the matter is arguable, or where the suggested answer in the answer key is even a plausible answer, the Court would not interfere. Where, however, the answer is demonstrably unacceptable, the Court would definitely interfere ex debito justitiae.”
This means that courts will not interfere merely because another answer is possible or the issue is debatable. Judicial intervention is warranted only where the official answer is clearly and indisputably incorrect.
No Opinion on Correctness of the Two Questions
Importantly, the High Court refrained from expressing any opinion on whether the petitioner’s answers to Questions 88 and 96 were actually correct.
The Bench stated that since the Tribunal had never examined the issue on merits, it would be appropriate for the Tribunal to consider the matter first.
Accordingly, the High Court left the factual determination regarding the disputed answers to the CAT.
High Court Orders Fresh Hearing by CAT
Setting aside the Tribunal’s earlier approach, the High Court directed the CAT to hear the matter afresh.
Considering that the dispute concerns the candidature of an aspirant seeking entry into the Indian Forest Service (IFS), the Bench requested the Tribunal to take up the matter on the very next date of hearing and dispose of it as expeditiously as possible.
The Court observed, “As this involves the candidature of a candidate for entry into the Indian Forest Service and the issue is short, we request the Tribunal to take up this matter on the next date of hearing finally and to take a view thereon as expeditiously as possible.”
Significance of the Judgment
The ruling is significant for candidates appearing in competitive examinations conducted by UPSC and other recruitment agencies.
The judgment reiterates that while courts ordinarily avoid interfering in academic evaluations, they retain the power to examine the legality of official answer keys where there is clear evidence that the prescribed answers are patently incorrect.
At the same time, the Court maintained that judicial review should remain limited and would not extend to cases involving merely debatable or plausible differences of opinion over the correct answer.
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