Shivansh Shrivas vs State Of Madhya Pradesh Through Pricnpal Secrerary Home Department
- Court
- Madhya Pradesh High Court
NEUTRAL CITATION NO. 2026:MPHC-IND:12170
1
W.P. No. 13534/2026
IN THE HIGH COURT OF MADHYA
PRADESH
AT INDORE
BEFORE
HON'BLE SHRI JUSTICE JAI KUMAR PILLAI
WRIT PETITION No. 13534 of 2026
SHIVANSH SHRIVAS AND OTHERS
Versus
STATE OF MADHYA PRADESH THROUGH PRICNPAL
SECRERARY HOME DEPARTMENT AND OTHERS
Appearance:
Shri Tanishq Patel - Advocate for the petitioners.
Shri Kushagra Singh –Dy.GA for the respondents/State.
Shri Rishabh Singh Chauhan -Advocate for the respondent
[R-3].
Reserved on : 18/04/2026
Post on : 29/04/2026
______________________________________________________
ORDER
Signature Not Verified
Signed by: HARIKUMAR
NAIR
Signing time: 4/29/2026
5:37:50 PM
NEUTRAL CITATION NO. 2026:MPHC-IND:12170
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W.P. No. 13534/2026
1. This present writ petition has been filed under Article 226 of
the Constitution of India, challenging the scheduling of the Sub-
Inspector Cadre Recruitment Mains Examination, 2025. The
petitioners are aggrieved by the action of the respondents in
scheduling the said examination on 29.04.2026, which falls merely
two days after the Madhya Pradesh Public Service Commission
(MPPSC) Preliminary Examination scheduled on 26.04.2026.
2. The primary relief sought by the petitioners is the issuance of
an appropriate writ or direction to the respondents to postpone or
reschedule the aforementioned Mains Examination in the interest of
justice. Furthermore, the petitioners pray for a direction to ensure a
reasonable time gap between the MPPSC Preliminary Examination
and the Sub-Inspector Mains Examination to provide a fair
opportunity, along with the imposition of costs and any other
appropriate relief.
Facts of the Case
3. The petitioners are bona fide aspirants for public employment
in the State of Madhya Pradesh and have been preparing for various
competitive examinations. The MPPSC issued its examination
calendar on 31.12.2025, wherein the Preliminary Examination was
scheduled to be conducted on 26.04.2026. The petitioners duly
applied for the same and submitted their online applications.
Signature Not Verified
Signed by: HARIKUMAR
NAIR
Signing time: 4/29/2026
5:37:50 PM
NEUTRAL CITATION NO. 2026:MPHC-IND:12170
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W.P. No. 13534/2026
4. Concurrently, the Sub-Inspector/Subedar Recruitment
Examination 2025 (first phase/online examination) was conducted
between 16.01.2026 to 21.01.2026. The results were subsequently
declared on 12.03.2026. The petitioners successfully qualified this
preliminary stage and became eligible to appear in the next stage of
the recruitment process.
5. Thereafter, the respondents issued a notification scheduling
the second phase, i.e., the Mains Examination for the Sub-Inspector
Recruitment 2025, on 29.04.2026. Recognizing the two-day gap
between the two examinations, the petitioners submitted a
combined representation requesting the postponement of the Mains
Examination. However, no action has been taken by the
respondents on the said representation till date.
Contentions of the Petitioner
6. The petitioners contend that the impugned schedule is
entirely arbitrary and unreasonable. They emphasize that despite the
prior ‘declaration of the MPPSC calendar, the respondents failed’ to
consider the same, thereby creating an unequal and unfair situation
for candidates appearing in both examinations, “inters alia ”.
7. It is pleaded that the petitioners ‘are the residents of the
Indore District which is well within the territorial jurisdiction of this
Hon’ble Court at Indore and are amenable to the writ jurisdiction of
Signature Not Verified
Signed by: HARIKUMAR
NAIR
Signing time: 4/29/2026
5:37:50 PM
NEUTRAL CITATION NO. 2026:MPHC-IND:12170
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W.P. No. 13534/2026
this Hon’ble Court and that the respondents are the instrumentalities
of the State’. The petitioners further submit that a large ‘number of
candidates appearing ‘in the MPSI examination are also
participating in the MPPSC examination, making overlapping
participation a foreseeable circumstance.
8. The petitioners argue that the respondents failed to ‘act in a
fair and ‘reasonable manner while exercising their administrative
discretion. The extensive syllabus, the introduction of negative
marking, and the fact that the examination is being held after a gap
of more than eight years demand adequate preparation time. The
lack of a reasonable gap prevents them from recovering, traveling
between different examination centres, and performing without
mental stress and physical fatigue.
Contentions of the Respondents
9. Per contra, the respondents have entered appearance and filed
their Reply/Return, vehemently opposing the writ petition. The
primary defense raised is that this Court possesses extremely
limited jurisdiction to interfere in matters involving the
administrative decisions and schedules fixed by an examining body.
10. The respondents submit that the administrative machinery for
the examination has already been mobilized. They state that the
admit cards have already been issued or are in the process of being
Signature Not Verified
Signed by: HARIKUMAR
NAIR
Signing time: 4/29/2026
5:37:50 PM
NEUTRAL CITATION NO. 2026:MPHC-IND:12170
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W.P. No. 13534/2026
issued, and the allotment of examination centres has been finalized.
Any change in the examination dates at this advanced stage would
result in a severe misuse of public funds and administrative chaos.
11. Furthermore, the respondents assert that a gap of two days is
entirely sufficient for candidates to travel between centres and
manage their logistics. They emphatically contend that the
impugned scheduling does not result in any violation of statutory
law or fundamental rights of the petitioners, and therefore, the
petition deserves to be dismissed outright.
Analysis and Conclusion
12. Having heard the pleadings and perused the record, this Court
must first outline the contours of judicial review under Article 226
of the Constitution of India in matters pertaining to academic or
recruitment examinations. The law is firmly established that the
constitutional courts must exercise immense restraint and refrain
from interfering with the schedules and policies determined by
examining bodies, as these authorities possess the requisite
administrative expertise.
13. The Hon'ble Supreme Court in the landmark case of
Maharashtra State Board of Secondary and Higher Secondary
Education v. Paritosh Bhupeshkumar Sheth [(1984) 4 SCC 27],
Signature Not Verified
Signed by: HARIKUMAR
NAIR
Signing time: 4/29/2026
5:37:50 PM
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W.P. No. 13534/2026
while discussing the scope of judicial interference, unequivocally
held as under:-
“29. Far from advancing public interest and fair play
to the other candidates in general, any such
interpretation of the legal position would be wholly
defeasive of the same. As has been repeatedly pointed
out by this Court, the Court should be extremely
reluctant to substitute its own views as to what is wise,
prudent and proper in relation to academic matters in
preference to those formulated by professional men
possessing technical expertise and rich experience of
actual day-to-day working of educational institutions
and the departments controlling them. It will be wholly
wrong for the Court to make a pedantic and purely
idealistic approach to the problems of this nature,
isolated from the actual realities and grass root
problems involved in the working of the system and
unmindful of the consequences which would emanate if
a purely idealistic view as opposed to a pragmatic one
were to be propounded. It is equally important that the
Court should also, as far as possible, avoid any
decision or interpretation of a statutory provision, rule
or bye-law which would bring about the result of
rendering the system unworkable in practice. It is
unfortunate that this principle has not been adequately
kept in mind by the High Court while deciding the
instant case.”
14. Evaluating the present case on these settled parameters, it is
an admitted position that the administrative process is at its final
stage. Admit cards have been issued or are being issued, and
Signature Not Verified
Signed by: HARIKUMAR
NAIR
Signing time: 4/29/2026
5:37:50 PM
NEUTRAL CITATION NO. 2026:MPHC-IND:12170
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W.P. No. 13534/2026
examination centres have been allotted. Rescheduling a state-level
recruitment examination at the eleventh hour would undoubtedly
derail the entire process and lead to a substantial misuse of public
funds, which this Court cannot permit.
15. Addressing the issue of practical hardship raised by the
petitioners, this Court finds merit in the respondents' submission
that a two-day gap between the MPPSC Preliminary Examination
(26.04.2026) and the Sub-Inspector Mains Examination
(29.04.2026) is sufficient to undertake necessary travel and
logistical arrangements. Personal inconvenience or the anxiety of a
few candidates cannot dictate the public employment calendar.
16. Most importantly, for a writ of mandamus to be issued, the
petitioners must demonstrate a crystal-clear breach of a statutory or
constitutional right. The right to participate in an examination is
governed strictly by the rules of the examining body. The
scheduling of two distinct examinations with a two-day gap does
not constitute any violation of law or fundamental rights enshrined
under the Constitution of India.
17. In view of the aforesaid analysis, this Court finds no legal
infirmity, arbitrariness, or jurisdictional error in the impugned
action of the respondents. The petitioners are not entitled to the
reliefs claimed. Accordingly, the Writ Petition is bereft of merit and
is hereby dismissed.
Signature Not Verified
Signed by: HARIKUMAR
NAIR
Signing time: 4/29/2026
5:37:50 PM
NEUTRAL CITATION NO. 2026:MPHC-IND:12170
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W.P. No. 13534/2026
18. Pending applications, if any, are disposed of accordingly.
No order as to costs.
(Jai Kumar Pillai)
Judge
hk/
Signature Not Verified
Signed by: HARIKUMAR
NAIR
Signing time: 4/29/2026
5:37:50 PM