Courts may interfere with examination answer keys only upon clear, demonstrable material error.

The petitioner, a candidate for the post of Assistant Director, Kisan Kalyan and Agriculture Development (Kshetra Vistar), challenged the answer key and examination results issued by the Madhya Pradesh Public Service Commission.

He sought correction/modification of the answers to Questions 12, 15, 31, 32, 40, 59, 60, 77, 84, 87, 92 and 93; omission of Questions 5, 9, 49, 57, 61 and 74; preparation of a revised merit list; and reservation of one post for him.

The respondents relied upon the Full Bench decision in Nitin Pathak v. State of M.P. & Others, W.A. No. 581 of 2017, dated 4 September 2017, concerning judicial review of disputed examination answer keys.

The petitioner opposed dismissal but was unable to distinguish his case from Nitin Pathak.

Whether the High Court, in exercise of judicial review, could direct correction or modification of disputed answer keys, omission of allegedly erroneous questions, or referral of the disputed questions to an expert committee?

Whether the petitioner had established, by clear and demonstrable material, that the answer key contained material errors warranting judicial interference with the examination result and merit list?

Whether the petitioner was entitled to consequential relief, including preparation of a revised merit list and reservation of one post?

The Court applied the Full Bench ruling in Nitin Pathak v. State of M.P. & Others, which held that courts should ordinarily leave disputed examination-answer-key questions to academicians and experts, should not appoint court-directed expert committees in the absence of mala fides, and should not act as appellate authorities over expert academic opinions; judicial review concerns the decision-making process rather than the correctness of the decision itself.

The Court also relied on Ran Vijay Singh v. State of Uttar Pradesh, (2018) 2 SCC 357, which holds that re-evaluation or scrutiny may be ordered only where the governing rules permit it or, in exceptional cases, where the candidate clearly demonstrates—without inferential reasoning or rationalisation—that the answer key contains a material error.

Courts must be extremely cautious in substituting their own views for those of experts and should not undertake re-evaluation of answer sheets.

The Supreme Court further recognised that, where permitted, exclusion of a demonstrably defective question may be an appropriate remedy, but the examination process should not ordinarily be unsettled merely because candidates are dissatisfied with an answer key.

The petitioner sought judicial correction of multiple answers and omission of several questions, thereby inviting the Court to reassess the examination answer key.

Applying Nitin Pathak, the Court held that such an exercise falls outside the normal scope of judicial review, particularly where no mala fides were alleged against the experts or examination authority.

Applying Ran Vijay Singh, the Court found that the petitioner had not demonstrated, through clear and conclusive material and without an inferential process of reasoning, that the disputed answers were materially incorrect.

Since the petitioner could not distinguish the facts of his case from Nitin Pathak, there was no basis to order re-evaluation, refer the questions to another expert body, revise the merit list, or reserve a post.

It declined to interfere with the disputed answer key or examination results because the petitioner failed to establish a clear and exceptional error warranting judicial review.

Consequently, the writ petition was dismissed, and no direction was issued for modification or omission of questions, preparation of a revised merit list, or reservation of a post.