Facts
The petitioner challenged the model answer key issued by the Madhya Pradesh Public Service Commission for Set-C of the General Studies paper, specifically in relation to Questions 55, 67 and 69.
Source reference: p.1, para.1He sought correction of the answer key, award of six additional marks, reassessment of the cut-off, and permission to participate in the mains examination.
Source reference: p.1, para.1The respondents contended that the controversy was already governed by the Full Bench decision in Nitin Pathak v. State of M.P., W.A. No. 581 of 2017, decided on 4 September 2017.
Source reference: p.1, para.2The petitioner could not distinguish the facts of his case from Nitin Pathak.
Source reference: p.1, para.3Issues
1. Whether the High Court, in exercise of judicial review under Article 226, should examine and correct the disputed answers in the examination authority’s model answer key.
Source reference: p.1, paras.1–3; p.2, para.42. Whether the petitioner was entitled to reassessment of his marks, revision of the cut-off, and permission to participate in the mains examination on the basis of the alleged errors in Questions 55, 67 and 69.
Source reference: p.1, para.13. Whether the petitioner had demonstrated a clear and material error in the answer key warranting judicial interference under the principles governing re-evaluation of examination papers.
Source reference: p.2, para.4Law Applied
The Court applied the Full Bench ruling in Nitin Pathak v. State of M.P., which held that courts should not ordinarily refer disputed answer keys to court-appointed experts and should defer to academicians and experts absent mala fides or a clear defect in the decision-making process.
Source reference: p.1, para.2It further relied on Ran Vijay Singh v. State of Uttar Pradesh, (2018) 2 SCC 357, which establishes that re-evaluation is permissible as of right only where the governing statute, rule or regulation so provides; otherwise, judicial intervention is justified only in rare and exceptional cases where the candidate demonstrates, clearly and without inferential reasoning, that the answer key contains a material error.
Source reference: pp.2–4, para.4Courts must not act as appellate authorities over expert academic opinions or undertake re-evaluation themselves.
Source reference: p.2, para.4Sympathy or perceived individual hardship cannot justify derailing the examination process.
Source reference: pp.3–4, para.4Reasoning
The Court found that the petitioner’s challenge concerned the correctness of expert-determined answers in the model answer key.
Source reference: pp.1–2, paras.2–4Under Nitin Pathak and Ran Vijay Singh, the Court’s review was confined to the legality of the decision-making process and did not extend to substituting its own academic assessment for that of the examination experts.
Source reference: pp.1–2, paras.2–4The petitioner was unable to distinguish his case from Nitin Pathak and did not establish any mala fide action or a clear, demonstrable material error in the disputed answers warranting exceptional interference.
Source reference: p.1, para.3; p.2, para.4Consequently, the Court declined to correct the answer key, reassess the petitioner’s marks, or interfere with the examination process.
Source reference: no citationHolding
The Court held that the petitioner was not entitled to judicial correction of the model answer key or re-evaluation of his answers because no exceptional or clearly demonstrable error warranting interference had been shown.
The claims for six additional marks, reassessment of the cut-off, and permission to participate in the mains examination were therefore rejected.
Source reference: no citationThe writ petition was dismissed.
Source reference: p.4, para.5Original Court PDF
Ravi MishravsMadhya Pradesh Public Service Commission Thr
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