Courts cannot round off or enhance examination marks absent governing regulatory authority.

The respondent, an IPS officer, was admitted to the Master of Laws (M.L.) degree course through private study during the academic year 2018–2019 and appeared for the examination under Registration No. ML18009.

He secured 59.91% marks and sought rounding off of his marks to 60% so as to obtain First Class.

The Single Judge allowed his writ petition, rounded off the marks to 60%, and directed consequential conferment of First Class, relying on State of U.P. v. Pawan Kumar Tiwari, (2005) 2 SCC 10.

The University of Madras and its Controller of Examinations preferred the intra-court appeal under Clause 15 of the Letters Patent.

Whether the principle applied in State of U.P. v. Pawan Kumar Tiwari could justify rounding off the respondent’s examination marks from 59.91% to 60% for awarding First Class.

Whether the High Court, in exercise of judicial review under Article 226 of the Constitution, could enhance or round off marks awarded by the University in the M.L. examination.

The Court applied the principle that evaluation of answer scripts and award of marks fall within the domain of examiners and academic experts, and courts exercising judicial review should not substitute their own assessment or alter the prescribed examination scheme.

Relying on West Bengal Joint Entrance Examination Board v. Sarit Chakraborty, (2015) 13 SCC 668, the Court held that rounding off marks is impermissible where there is no enabling provision in the applicable guidelines, regulations, or examination scheme.

The Court also relied on Y. John Edward v. Chairman, Tamil Nadu Uniformed Services Recruitment Board, 2018 SCC OnLine Mad 12019, which distinguished Pawan Kumar Tiwari on the ground that it concerned calculation of reserved-category posts and did not authorise the award or rounding off of examination marks.

The Court further emphasised that even a difference of 0.01 marks may affect competitive outcomes and that courts must avoid granting additional marks on grounds of sympathy or leniency.

The Division Bench held that the respondent’s score of 59.91% could not be judicially converted into 60% because the evaluation and award of marks were matters for the University’s academic authorities, not the Court.

The reasoning in Pawan Kumar Tiwari was inapplicable because that decision did not concern alteration of marks in an academic examination.

In the absence of any University rule or examination guideline permitting rounding off, the Single Judge’s direction was inconsistent with the principle stated in Sarit Chakraborty.

The Court also considered that granting such relief could prejudice other candidates and encourage similar claims, thereby disturbing the examination scheme and creating wider administrative consequences.

The respondent’s status as an IPS officer did not provide a legal basis for granting the requested concession.

It held that the High Court could not round off 59.91% to 60% or confer First Class in the absence of authority under the University’s examination rules.

The writ order dated 08 July 2022 in W.P. No. 11821 of 2022 was set aside, the writ appeal was allowed, and the connected civil miscellaneous petition was closed.

No costs were awarded.