CAT - ['Allahabad']
Employment and Labour LawAdministrative and Public Law

Authorities must provide reasoned reconsideration of answer-key objections before deciding promotion on merit.

Aniruddha Kumar Shukla vs General Manager N C Rly

CAT - ['Allahabad']JUDGMENT: September 02, 20263 MIN READSOURCE JUDGMENT
Authorities must provide reasoned reconsideration of answer-key objections before deciding promotion on merit.. Aniruddha Kumar Shukla vs General Manager N C Rly. CAT - ['Allahabad']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant challenged the panel dated 23 August 2018 for promotion to the post of Loco Inspector in Pay Matrix Level-7, Grade Pay of ₹4,600, pursuant to the notification dated 11 January 2016.

Source reference: para. 3

Although 38 vacancies were notified, the applicant was not empanelled on the ground that he had not qualified in the written examination.

Source reference: para. 3

He contended that 11 answers in the model answer key were incorrect and that his answers were correct under the applicable Railway rules and manuals.

Source reference: para. 3

He submitted a detailed representation dated 11 February 2019, which remained undecided.

Source reference: para. 3

The respondents maintained that the answer sheets had been evaluated uniformly in accordance with the model answer key and that the question-paper setter had retired on 31 January 2019.

Source reference: para. 4

A report dated 4 June 2019 by the Selection Committee stated that the answers had been evaluated according to the model answer key.

Source reference: para. 5

However, the Tribunal found that the Committee had not adequately addressed the applicant’s detailed objections, which were supported by relevant rules and manuals.

Source reference: para. 5
02

Issues

Whether the respondents’ failure to adequately examine and decide the applicant’s objections regarding 11 allegedly incorrect answers in the model answer key rendered the selection process liable to reconsideration.

Source reference: paras. 3–6

Whether the applicant was entitled to consideration for promotion on merit if any discrepancy in the model answer key was found.

Source reference: para. 6
03

Law Applied

The Tribunal applied the administrative-law principle that a public authority must meaningfully and objectively consider a candidate’s specific objections affecting his selection prospects and must provide a satisfactory, reasoned determination.

Source reference: paras. 4–6

Uniform application of an answer key does not, by itself, resolve a substantial challenge alleging that the key contains incorrect answers, particularly where the challenge is supported by applicable service rules or manuals.

Source reference: paras. 4–6

The Tribunal further directed that, where necessary, an expert committee may be constituted to examine the alleged discrepancies, and that any resulting correction must be followed by consideration of the candidate according to merit.

Source reference: para. 6

No specific statutory provision or judicial precedent was cited in the order.

Source reference: no citation
04

Reasoning

The Tribunal accepted that the respondents had evaluated the candidates using the same model answer key, but held that this did not adequately answer the applicant’s grievance.

Source reference: paras. 4–6

The applicant had identified 11 questions and supported his claimed answers by referring to relevant Railway rules and manuals.

Source reference: para. 3

Although the Senior DPO had referred the complaints to the Selection Committee, the Committee’s report merely stated that it had followed the model answer key and did not examine the applicant’s substantive objections.

Source reference: para. 5

Since the correctness of the answer key could directly affect the applicant’s eligibility and comparative merit, the Tribunal considered a detailed reconsideration necessary, including expert scrutiny if required.

Source reference: para. 6
05

Holding

The Original Application was disposed of without directly quashing the panel or granting promotion.

The competent authority was directed to reconsider the applicant’s grievance dated 11 February 2019, along with the recommendation of the Senior DPO dated 14 March 2019, in detail within three months.

Source reference: para. 6

If necessary, an expert committee was to be constituted to examine the alleged discrepancies in the model answer key.

Source reference: para. 6

If any discrepancy was found, the applicant was to be considered for the post of Chief Loco Inspector according to his merit pursuant to the notification dated 11 January 2016.

Source reference: para. 6
CAT - ['Allahabad']

Original Court PDF

Aniruddha Kumar ShuklavsGeneral Manager N C Rly

CAT - ['Allahabad'] · September 02, 2026

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