Facts
The petitioners appeared in the T-TET 2024 Paper-I examination for teachers of Classes I–V.
Source reference: p.3The prospectus prescribed 90 out of 150 marks as the qualifying threshold for unreserved candidates, with the applicable qualifying standards for reserved categories.
Source reference: p.3The examination was conducted on 4 May 2025, and the final answer key was published on 9 June 2025.
Source reference: p.3A disputed question—“Anarchic Theory of Intelligence is known as”—appeared in different numerical positions in Booklet Series A, B and C, with “None of the above” treated as the correct answer in the 2024 final key.
Source reference: p.4The petitioners contended that the same question had appeared in T-TET 2022, when “Group Factor Theory” had been treated as the correct answer, and that they had answered the 2024 question accordingly.
Source reference: p.4Each petitioner allegedly secured one mark below the qualifying threshold.
Source reference: p.4Although the petitioners did not challenge the tentative answer key within the prescribed period, they later submitted representations seeking correction of the answer and addition of one mark.
Source reference: pp.7–9In an earlier writ petition, WP(C) No. 398 of 2025, the High Court directed the authorities to refer the representation to an expert body and take a reasoned decision.
Source reference: p.5A three-member Expert Committee thereafter upheld “None of the above” as the correct answer, and the decision was communicated to the petitioners on 8 August 2025.
Source reference: p.9The petitioners then filed the present writ petition seeking addition of one mark each and consequential inclusion in the select list.
Source reference: pp.2–3Issues
1. Whether the petitioners were entitled to an additional one mark in T-TET 2024 Paper-I on the ground that the disputed question had previously been answered differently in the T-TET 2022 final answer key.
Source reference: pp.4, 10–152. Whether the High Court could interfere with the Expert Committee’s determination of the correct answer under Article 226 of the Constitution.
Source reference: pp.10–133. Whether the respondents’ failure to place on record the reasoning or material supporting the Expert Committee’s conclusion rendered the rejection of the petitioners’ claim unsustainable.
Source reference: pp.10–15Law Applied
The Court applied the principle that judicial review ordinarily does not permit a constitutional court to act as a subject expert or substitute its own view for that of an expert committee in academic and examination matters.
Source reference: pp.11–12This principle was supported by H.P. Public Service Commission v. Mukesh Thakur, (2010) 6 SCC 759, and Central Board of Secondary Education v. Khushboo Shrivastava, (2014) 14 SCC 523, which caution against judicial re-evaluation of answer keys.
Source reference: pp.11–12The Court also referred to Vikesh Kumar Gupta v. State of Rajasthan, (2021) 2 SCC 309, and the decisions concerning deference to expert opinions, while noting that interference may be justified where the authority fails to disclose a rational or evidentiary basis for its decision.
Source reference: pp.11–13The applicable T-TET instructions required candidates to challenge tentative answers within the prescribed period and in the prescribed manner.
Source reference: pp.7–9The Court also considered the principle in Hukam Chand Shyam Lal v. Union of India, AIR 1976 SC 789, that where a power is required to be exercised in a particular manner, it must be exercised in that manner and not otherwise.
Source reference: p.10Reasoning
The Court acknowledged that the petitioners had not challenged the disputed question during the prescribed objection period and that the respondents had obtained an Expert Committee’s opinion.
Source reference: pp.7–10Ordinarily, the Court would not reassess the correctness of an answer key or substitute its own academic view for that of the experts.
Source reference: pp.7–10However, the Court found that the respondents had not placed on record the materials, reasoning, or concrete basis on which the Expert Committee concluded that “None of the above” was correct.
Source reference: p.10The respondents merely relied on the existence of the Expert Committee’s decision and argued that the 2022 answer had not been challenged.
Source reference: p.10The Court rejected that reasoning, observing that the absence of a challenge in 2022 could not by itself establish that the 2022 answer was incorrect, particularly when no corrective notice had been issued at that time.
Source reference: p.10The Court further held that the respondents had failed to explain why “Group Factor Theory,” which had been accepted as the correct answer in the T-TET 2022 final answer key, should be rejected in 2024, despite the petitioners having relied on that answer while attempting the examination.
Source reference: pp.10–11In the absence of a disclosed and convincing basis for the change, the Court concluded that one mark had been deducted from each petitioner without adequate justification.
Source reference: p.11The authorities’ reliance on precedents requiring deference to expert bodies was therefore held distinguishable on the facts.
Source reference: p.12Holding
The writ petition was allowed.
The Court held that the respondents had failed to justify the change in the answer to the disputed question and had not adequately supported the Expert Committee’s conclusion.
Source reference: pp.10–15The respondents were directed to award one additional mark to each petitioner in the T-TET 2024 Paper-I result within two months and to declare their results accordingly.
Source reference: p.15The petition was disposed of, and any pending applications were also disposed of.
Source reference: p.15Original Court PDF
Smt. Sharmishta Deb and 8 OthersvsThe State of Tripura and 4 Others
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