Absence of statutory provision and manifest error precludes judicial direction for re-evaluation of medical examination answer scripts.

The respondents are postgraduate medical students (M.D./M.S.) under the Rajiv Gandhi University of Health Sciences (RGUHS).

In the September 2025 examinations, the students secured an aggregate of 50% or more (at least 200/400 marks) but failed to meet the mandatory requirement of securing a minimum of 40% (40/100 marks) in each of the four theory papers.

For instance, in the lead case, the student secured an aggregate of 201 marks but received 39 marks in Paper III after the average of two evaluators was taken (40 and 38 marks respectively).

The students filed writ petitions seeking re-evaluation.

A learned Single Judge allowed the petitions and directed a third evaluation on the grounds of "substantial justice and equity," as the students had passed the aggregate threshold.

The University and the National Medical Commission (NMC) appealed this decision.

Whether the High Court can direct the re-evaluation of answer scripts in the absence of any provision for the same in the governing regulations.

Whether securing the aggregate passing marks constitutes an "exceptional circumstance" or "material error" justifying judicial interference on grounds of equity.

Whether the 15% variation threshold for a third valuation under Regulation 8.4(b) refers to the total marks prescribed for the paper or the marks actually awarded.

The Court applied Regulation 8.4 of the Post-Graduate Medical Education Regulations, 2023, which stipulates a twin passing criteria (50% aggregate and 40% per paper) and expressly prohibits re-evaluation under Regulation 8.4(c).

It relied on the Supreme Court precedents in Maharashtra State Board of Secondary and Higher Secondary Education v. Paritosh Bhupeshkumar Sheth, establishing that in the absence of a statutory provision, candidates have no right to claim re-evaluation.

It relied on the Supreme Court precedents in Pramod Kumar Srivastava v. Phase BPSC, establishing that in the absence of a statutory provision, candidates have no right to claim re-evaluation.

It further applied the "material error" exception from Ran Vijay Singh v. State of Uttar Pradesh, noting that re-evaluation is permitted only in rare cases of demonstrable error without inferential reasoning.

It further applied Dr. NTR University of Health Sciences v. Dr. Yerra Thrinadh, which held that sympathy or compassion has no role in directing re-evaluation.

The Court reasoned that the criteria for passing—meeting both aggregate and individual paper thresholds—are well-defined and not unusual; thus, failing one paper while passing the aggregate is not an "exceptional circumstance."

The Court found that the Single Judge erred by invoking "equity," as judicial interference is impermissible when Regulation 8.4(c) contains an express prohibition against re-evaluation.

Regarding the evaluation process, the Court noted there were no allegations of malpractice or incompetence.

Addressing the "15% variation" rule in Regulation 8.4(b), the Court held that despite the petitioners' argument for a relative percentage, the plain language "15% of the total marks prescribed for the paper" refers to 15% of the maximum marks (i.e., 15 marks out of 100), and the Court cannot interpret it otherwise regardless of the perceived logic of the object of the regulation.

It held that the High Court cannot order re-evaluation based on sympathy or equity when the statutory regulations (Post-Graduate Medical Education Regulations, 2023) expressly prohibit it and prescribe specific passing criteria.

The Court further clarified that the 15% variation required to trigger a third valuation must be calculated against the maximum prescribed marks for the paper, not the marks awarded.