In the absence of statutory provisions, courts cannot direct re-evaluation of answer scripts on grounds of equity.

The respondents (original writ petitioners) were PG medical students under the Rajiv Gandhi University of Health Sciences (RGUHS).

In the September 2025 examinations, they secured an aggregate of 50% or more marks across four theory papers but failed to secure the mandatory minimum of 40 marks in one specific paper.

Under Regulation 8.4 of the Post-Graduate Medical Education Regulations, 2023 ("2023 Regulations"), their papers were evaluated by two examiners, and the average was taken as the final result.

The students sought a writ of mandamus for re-evaluation/third evaluation by a new examiner.

A Learned Single Judge allowed the writ petitions on "grounds of equity" and "substantial justice," directing a third evaluation.

The University and the National Medical Commission (NMC) appealed this decision.

1. Whether the Court can direct re-evaluation of answer scripts in the absence of a statutory provision or where such re-evaluation is expressly prohibited by regulations.

2. Whether securing the aggregate pass marks while failing in a individual paper constitutes an "exceptional circumstance" warranting judicial interference on grounds of equity.

3. Whether the requirement for a third evaluation under Regulation 8.4(b) (triggered by a 15% difference) refers to 15% of the "maximum marks" or 15% of the "marks awarded".

The Court primarily applied Regulation 8.4 of the Post-Graduate Medical Education Regulations, 2023, which mandates two valuations, stipulates a third valuation only if the difference between the two is 15% or more of the "total marks prescribed" (i.e., 100 marks), and expressly prohibits re-evaluation under Regulation 8.4(c).

It relied on *Maharashtra State Board of Secondary and Higher Secondary Education v. Paritosh Bhupeshkumar Sheth* [(1984) 4 SCC 27], which established that courts cannot order re-evaluation if rules prohibit it.

It further applied *Ran Vijay Singh v. State of U.P.* [(2018) 2 SCC 357] and *Dr. NTR University of Health Sciences v. Dr. Yerra Thrinadh* [(2022) 18 SCC 716], which held that sympathy or equity cannot override statutory examination rules and that re-evaluation is permissible only in rare cases of demonstrated "material error".

The Division Bench observed that there were no allegations of malpractice, procedural irregularity, or evaluator incompetence.

The Court found the Single Judge's reliance on "equity" to be legally flawed, stating that the criteria for passing (50% aggregate AND 40% per paper) are well-defined and must be strictly followed.

Regarding the 15% variation rule in Regulation 8.4(b), the Court noted that while pegging the variation to "marks awarded" might be more logical, the plain language of the statute refers to "total marks prescribed for the paper" (100 marks); thus, a third evaluator is only triggered if the marks differ by at least 15 absolute points.

Since the petitioners did not meet this threshold and Regulation 8.4(c) explicitly barred re-evaluation, the Court held it could not exercise its powers under Article 226 to bypass statutory prohibitions.

It held that "total marks prescribed" means the maximum marks (100) and not the marks obtained.

Consequently, the Division Bench allowed the appeals, set aside the orders of the Learned Single Judge, and dismissed the original writ petitions.