Facts
The petitioners applied for the post of Sub Inspector of Police 2025 pursuant to notification No. 1 of 2025 dated 04.04.2025.
Source reference: p.1, 3The recruitment process included a Part-I Tamil Eligibility Test and a Part-II Main Written Examination consisting of General Knowledge (Part-A) and Psychology (Part-B).
Source reference: p.3-4The petitioners challenged the selection list, alleging that the Part-II, Part-B exam deviated from the prescribed syllabus and past patterns (2022/2023) by omitting 10 specific Tamil language questions and replacing them with 10 psychology questions.
Source reference: p.4They sought a Mandamus to quash the results and conduct a fresh examination or re-evaluation based on "legitimate expectation".
Source reference: p.2, 5Issues
1. Whether the omission of specific Tamil language questions in Part-II (Part-B) constituted a material deviation from the syllabus or a violation of the doctrine of legitimate expectation.
Source reference: p.7 / para. 9-102. Whether the court should interfere with the recruitment process and order re-evaluation due to changes in the examination pattern.
Source reference: p.9 / para. 14Law Applied
The court primarily applied the Doctrine of Legitimate Expectation as interpreted in Union of India v. Hindustan Development Corporation, holding that an expectation must be founded on law, custom, or established procedure, not merely on hope or a desire to see past patterns repeated.
Source reference: p.8 / para. 10It further relied on Ran Vijay Singh v. State of UP, which establishes that judicial interference in academic/examination matters is limited to rare cases of "material error" and that the process should not be derailed simply because candidates are dissatisfied.
Source reference: p.9-10 / para. 14The court also noted that the Tamil Nadu Police Subordinate Service Rules provide broad discretion to the recruiting authority regarding exam content.
Source reference: p.5 / para. 6Reasoning
The Court found that while the 2022 and 2023 exams included 10 Tamil questions in Part-II, the current notification did not guarantee the same pattern.
Source reference: p.7-8 / para. 9-11The syllabus for Part-B was "indicative" and included broad categories like logical analysis, numerical analysis, communication skills, and mental ability; the replaced questions (logical reasoning and mathematics) fell within these existing categories.
Source reference: p.7, 9 / para. 8, 12The Court reasoned that since the candidates’ Tamil proficiency was already rigorously tested in Part-I (a 100-mark eligibility test), the absence of Tamil questions in Part-II did not constitute a "material error".
Source reference: p.5, 9 / para. 5, 13Furthermore, the authority to set the question paper rests with the recruiting board, and as long as the questions remain within the broad framework of the syllabus, the Court cannot interfere.
Source reference: p.8-9 / para. 11-13Holding
The Court dismissed the writ petition, holding that the petitioners failed to prove a legal mandate for a specific question-split or a material deviation from the syllabus.
The Court answered that the doctrine of legitimate expectation does not apply to the specific pattern of a question paper.
Source reference: p.8 / para. 11While dismissing the plea, the Court expressed a "fond hope" that the Board might include exclusive Tamil questions in future Main Examinations to further the objective of the 20% PSTM (Persons Studied in Tamil Medium) reservation.
Source reference: p.10 / para. 15-16All connected miscellaneous petitions were closed without costs.
Source reference: p.11 / para. 16Original Court PDF
B. Gurusamy & Anr. v. The Director General of Police / Chairman, TNUSRB & Ors. [2026:MHC:979 (WP(MD)No.2673 of 2026)]
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