Facts
The petitioner appeared in the BPSC 71st Combined Preliminary Competitive Examination. He scored 86.67 marks, below the unreserved-category cut-off of 88, and therefore did not qualify for the Mains examination.
Source reference: p. 5, paras. 8–9He challenged the marking of Question 66, which asked when Nalanda University was re-established in Bihar. The BPSC treated option D (2014) as correct; the petitioner had selected option A (2007).
Source reference: pp. 6–7, paras. 10–13The BPSC stated that experts had reviewed the answer key and retained 2014 as the correct answer because the University began functioning that year; the petitioner filed no rejoinder or material challenging the experts’ opinion.
Source reference: p. 4, paras. 5–6Issues
1. Whether the Court should interfere under Article 226 with the BPSC’s evaluation of Question 66 and the expert determination that option D (2014) was correct.
Source reference: pp. 4–7, paras. 5–132. Whether the petitioner established grounds for correction of his score from 86.67 to 88 and consequential qualification for the Mains examination.
Source reference: p. 5, paras. 8–9; p. 14, paras. 17–19Law Applied
In Central Board of Secondary Education v. Khushboo Shrivastava, (2014) 14 SCC 523, the Supreme Court held that courts should not substitute their views for examiners’ in academic matters.
Source reference: p. 8, para. 14In Ran Vijay Singh v. State of Uttar Pradesh, (2018) 2 SCC 357, the Court held that where the governing rules do not provide for re-evaluation, judicial intervention is permissible only in rare or exceptional cases where a material error is demonstrated clearly, without inferential reasoning; courts should presume the answer key correct, defer to academic expertise, and give the examination authority the benefit of doubt.
Source reference: pp. 9–12, para. 15The Patna High Court applied the same principles in Bihar Public Service Commission v. Ashish Kumar Pathak, 2021 (1) PLJR 588 (DB), holding that courts should not re-evaluate answer sheets or act as appellate bodies over experts, absent an opinion that is facially absurd or wrong.
Source reference: p. 13, para. 16Reasoning
The Court treated the correctness of the answer key as an academic matter and noted that BPSC’s experts had considered the contested question and retained 2014 because the University began functioning that year.
Source reference: p. 4, para. 5Although the petitioner argued that the question concerned re-establishment rather than commencement of functioning, he filed no rejoinder or supporting material to demonstrate that the expert conclusion was materially erroneous or facially absurd.
Source reference: pp. 4, 6–7, paras. 6, 11–13Applying the principles of judicial restraint in examination matters, the Court declined to determine the answer itself or substitute its assessment for that of the experts.
Source reference: pp. 8–14, paras. 14–17Holding
The Court held that the petitioner had not established a basis for judicial interference or for correction of his marks.
It found no merit in the writ application and dismissed it; no relief was granted.
Source reference: p. 14, paras. 17–19Original Court PDF
Ankit KashyapvsThe State of Bihar
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