Courts should not direct answer-sheet re-evaluation absent statutory provision, save for rare, clearly proven material error.

The petitioner, an aspirant for the post of Teacher in a Middle School under the Teacher Recruitment Examination-2, conducted pursuant to Advertisement No. 27/2023, submitted her application and appeared in the examination under Roll No. 375209.

After publication of the result, she claimed that she expected 68 marks based on her answers, but the Bihar Public Service Commission awarded her only 40 marks on evaluation of her OMR answer sheet.

She therefore filed the writ petition seeking re-examination/re-evaluation of her OMR sheet and issuance of a fresh mark sheet.

The respondents opposed the petition, contending that the petitioner had not produced the advertisement or any statutory provision, document, or communication permitting re-evaluation after publication of the result.

1. Whether a candidate can seek re-evaluation or re-examination of an answer sheet in the absence of a statutory, regulatory, or other applicable provision permitting such re-evaluation.

2. Whether, on the material produced by the petitioner, the Court should direct the Bihar Public Service Commission to re-evaluate her OMR answer sheet.

The Court applied the principle that re-evaluation of examination answer sheets cannot ordinarily be directed in the absence of a provision in the governing statute, rule, or regulation.

Relying on Ran Vijay Singh v. State of Uttar Pradesh, (2018) 2 SCC 357, the Court noted that where re-evaluation or scrutiny is expressly permitted, it may be undertaken in accordance with the governing rules; where it is not permitted, judicial intervention is permissible only in rare or exceptional cases upon a clear demonstration of material error, without inferential reasoning or rationalisation.

Courts should not themselves re-evaluate answer sheets, should ordinarily presume the correctness of the answer key, and should give the benefit of doubt to the examination authority rather than the candidate.

The petitioner sought re-evaluation principally on the basis of the difference between the marks she expected and the marks awarded by the Commission.

However, she failed to place on record the advertisement or any rule, document, letter, or order conferring a right or otherwise permitting her to seek re-evaluation of the OMR sheet after publication of the result.

Applying the restrictive principles laid down in Ran Vijay Singh, the Court held that the absence of an applicable provision, coupled with the failure to demonstrate any clear and exceptional material error, did not justify judicial direction for re-evaluation.

The Court also declined to undertake or compel an academic re-assessment of the answer sheet.

The writ petition was accordingly closed, without directing the Bihar Public Service Commission to re-examine the answer sheet or issue a fresh mark sheet.