B.Gurusamy vs The Director General of Poli

2026:MHC:979
WP(MD)No.2673 of 2026
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
RESERVED ON : 25.02.2026
DELIVERED ON : 11.03.2026
CORAM:
THE HONOURABLE MR.JUSTICE B.PUGALENDHI
WP(MD)No.2673 of 2026
&
WMP(MD)Nos.2267, 2269, 2270, 2274 of 2026
1.B.Gurusamy
2.S.Anandaraja : Petitioners
Vs.
1.The Director General of Police / Chairman,
Tamil Nadu Uniformed Services Recruitment Board,
Old Commissioner of Police Complex,
Pantheon Road, Egmore, Chennai – 600 008.
2.The Member Secretary,
Tamil Nadu Uniformed Services Recruitment Board,
Pantheon Road, Egmore, Chennai – 600 008.
3.The Superintendent of Police,
Tirunelveli District, Tirunelveli.
4.The Superintendent of Police,
Tenkasi District, Tenkasi. : Respondents
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WP(MD)No.2673 of 2026
PRAYER: Petition filed under Article 226 of the Constitution of India
seeking issuance of a Writ of Certiorarified Mandamus calling for the
records relating to the impugned notification No.1 of 2025 published by
the second respondent dated 04.04.2025 for direct recruitment to the post
of Sub Inspector of Police 2025 insofar as it relates to Part II Main Written
Examination Part B (Psychology Test and Communication Skills) and
subsequent publication of result of the impugned Provisional Selection
List SI 2025 by the second respondent through online dated Nil on the
ground that the same was done with deviation from syllabus, sudden
change in the exam pattern particularly omission of the Tamil Language
questions in the Part II Main Written Examination held on 21.12.2025,
quash the same and consequently, directing the second respondent to
conduct fresh examination or re-evaluate the Part II Main Written
Examination in accordance with the official syllabus based on the
petitioners' representations dated 06.01.2026 and 23.01.2026.
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WP(MD)No.2673 of 2026
For Petitioners : Mr.N.Marimuthu
For Respondents: Mr.Veera Kathiravan,
Additional Advocate General
Assisted by
Mr.C.Venkatesh Kumar,
Special Government Pleader
*
ORDER
This writ petition is filed as against the notification dated
04.04.2025 issued for the recruitment of Sub Inspector of Police and the
provisional selection list published by the second respondent.
2.The second respondent / Tamil Nadu Uniformed Services
Recruitment Board has issued a notification on 04.04.2025 for the
recruitment to the post of Sub Inspector of Police. These writ petitioners
have applied for and attended the exams conducted pursuant to the
notification. As per the notification, the pattern of examination is as
under:
(1) Part-I – Tamil Eligibility Test consisting of 100 questions
for 100 marks. The candidates who obtain the minimum marks of 40
will become eligible for evaluation of their main written examination.
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WP(MD)No.2673 of 2026
(2) Part-II – consisting of main written examination of Part-A
(General Knowledge) and Part-B (Psychology) carrying a total of 70
marks. The candidates are required to obtain a minimum of 25 marks
to qualify this main written examination and based on these marks,
the candidates are invited for certificate verification and physical
endurance test.
3.According to the petitioners, the syllabus for Part-B of Part-II of
the main written examination includes the testing of communication
skills of the candidates in effective usage of Tamil and English
Language. However, in the question paper for Part-B of Part-II of the
main written examination for the present year, questions with respect to
the effective usage of Tamil Language have been omitted and the same
has been replaced with 10 psychology related questions.
4.Learned Counsel for the petitioners pointed out that the question
papers for the examinations conducted during the year 2022 and 2023
included 10 questions specifically related to the effective usage of Tamil
Language. However, the examination pattern has been changed this year
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WP(MD)No.2673 of 2026
against the syllabus and previous year question papers. The petitioners,
who had a legitimate expectation that the questions would be asked as
per the syllabus and the pattern of the previous years, have lost marks as
a result of the change in the examination pattern. Therefore, he prayed
for appropriate orders.
5.On the other hand, it is submitted by the learned Additional
Advocate General that preference has been given exclusively for Tamil
Language in the Tamil Language Eligibility Test conducted in Part-I for
100 marks. Therefore, the knowledge and the proficiency of the
candidates in Tamil have already been tested in Part-I of the
examination.
6.He further submitted that the Tamil Nadu Police Subordinate
Service Rules only prescribes the conduct of a written examination for 70
marks and the Rules do not mandate a detailed syllabus or require the
inclusion of questions from every component. The syllabus, which was
issued, was only indicative in nature and meant to guide the candidates
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WP(MD)No.2673 of 2026
regarding the broad areas of preparation. The syllabus only provided
that effective use of Tamil and English Languages “will be” tested,
which is a predictive phrase and not binding in nature. The inclusion or
exclusion of particular types of questions within the framework of the
syllabus is within the discretion of the recruiting authority and therefore,
the doctrine of legitimate expectation would not arise in the present case.
Hence, he prayed for dismisssal.
7.This Court considered the rival submissions made on either side
and also perused the materials placed on record.
8.The second respondent / Tamil Nadu Uniformed Services
Recruitment Board has issued a notification on 04.04.2025 for the
recruitment to the post of Sub Inspector of Police. As per the
examination pattern, Part-B of Part-II of the main written examination
carries 30 marks for 60 objective type questions with each question
carrying half a mark. The Syllabus prescribed for Part-II of the main
written examination is extracted as under:
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WP(MD)No.2673 of 2026
“i. Logical Analysis: Analysis of any information logically to
find out various dimensions of the information.
ii. Numerical Analysis: Quick response with regard to the
numerical ability will be tested.
iii. Communication Skills: Effective usage of Tamil and English
Languages will be tested.
iv. Information Handling Ability: For any given information,
various aspects of the information, inferences and connected facts will
be tested.
v. Mental Ability: To test the candidate’s ability to draw
conclusions through inductive or deductive reasoning.”
9.Admittedly, the question papers for Part-B of Part-II of the main
written examination conducted during the years 2022 and 2023 included
10 exclusive Tamil questions testing the language, synonyms and the
meanings for various Tamil words and these questions were not asked
in English language. However, in the examination conducted during the
year 2025, these questions have been replaced by questions related to
logical reasoning such as number sequencing, code words, statements
and conclusions and mathematical questions. Therefore, the petitioners
claim that their legitimate expectation has been defeated.
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WP(MD)No.2673 of 2026
10.Since the claim of the petitioners is based on the doctrine of
legitimate expectation, it would be relevant to refer to the decision of the
Hon’ble Supreme Court in Union of India & Others v. Hindustan
Development Corporation & Others [ (1993) 3 SCC 499 ], wherein it was
held that the legitimacy of an expectation can be inferred only if it is
founded on the sanction of law or custom or an established procedure
followed in regular and natural sequence. It cannot be based on a wish
or desire or hope and it should be based on a legal obligation.
11.In the present case, it is pertinent to note that the notification
does not prescribe that the examination pattern of the previous years
would be followed in the present year as well. Since the setting of
syllabus is within the discretion of the recruiting authority, no legitimate
expectation can be claimed that the same pattern would be followed
every year.
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WP(MD)No.2673 of 2026
12.Moreover, the questions replacing the exclusive Tamil language
questions are questions related to logical reasoning such as number
sequencing, code words, statements and conclusions and mathematical
questions, which are also included in the syllabus of Part-B. Therefore,
even though the specific questions from Tamil language have not been
included in the question paper, the replaced questions are within the
broad syllabus prescribed by the Board.
13.To be noted, the syllabus does not provide the break-up of the
components within Part-B (Psychology Test) and as such, the candidates
are expected to prepare for all the components. It is not the case of the
petitioners that questions totally out of the scope of the syllabus have
been included in the question papers, warranting the interference of this
Court.
14.As held by the Hon'ble Supreme Court in Ran Vijay Singh v.
State of UP [ (2018) 2 SCC 357 ], the scope for High Courts to interfere in
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WP(MD)No.2673 of 2026
academic matters is limited and they can permit re-evaluation or
scrutiny of the answer sheet in rare or exceptional cases, only if it is
demonstrated that a material error has been committed. The Hon'ble
Supreme Court further held that the entire examination process cannot
be derailed, merely because some of the candidates are disappointed or
dissatisfied or perceive some injustice having caused to them by an
erroneous question or erroneous answer.
15.For the reasons aforesaid, this Court is not inclined to entertain
this writ petition. However, it must be pointed out that a horizontal
reservation of 20% is provided for Persons Studied in Tamil Medium
(PSTM) as per the notification. The objective of this policy is to support
the candidates who have studied in Tamil Medium. Therefore, it would
be appropriate if exclusive Tamil questions are also included in the main
examination, in future, to support this objective.
16.With the fond hope that the above suggestion would be taken
into account while setting question papers in the future, this writ
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WP(MD)No.2673 of 2026
petition is dismissed. There shall be no order as to costs. Consequently,
connected miscellaneous petitions are closed.
11.03.2026
Internet : Yes
gk
To
1.The Director General of Police / Chairman,
Tamil Nadu Uniformed Services Recruitment Board,
Old Commissioner of Police Complex,
Pantheon Road, Egmore, Chennai – 600 008.
2.The Member Secretary,
Tamil Nadu Uniformed Services Recruitment Board,
Pantheon Road, Egmore, Chennai – 600 008.
3.The Superintendent of Police,
Tirunelveli District, Tirunelveli.
4.The Superintendent of Police,
Tenkasi District, Tenkasi.
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WP(MD)No.2673 of 2026
B.PUGALENDHI, J.
gk
WP(MD)No.2673 of 2026
11.03.2026
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