Madhya Pradesh High Court

In the absence of statutory provisions, re-evaluation of answer scripts cannot be claimed as a matter of right.

Smt Arpna Patel vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: May 07, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a student of P.B.B.Sc. Nursing at Yogmani Institute of Nursing College, appeared for her second-year examinations in May 2025.

Source reference: para. 2

She was declared failed (compartment) in "Introduction to Education Nursing" and "Mental Health Nursing," securing 48 and 43 marks respectively against a passing requirement of 50.

Source reference: para. 2

Her application for revaluation was rejected on November 25, 2025, with no change in marks.

Source reference: para. 3

Upon obtaining her answer sheets via the RTI Act, she alleged irregularities, claiming answers were mechanically marked with crosses or given disproportionately low marks despite being correct.

Source reference: para. 3

Consequently, she filed this writ petition seeking a direction for re-evaluation by an independent examiner.

Source reference: para. 1
02

Issues

1. Whether the Court can direct a re-evaluation of answer scripts in the absence of a statutory or regulatory provision permitting the same.

Source reference: para. 7, 9

2. Whether the evaluation process was so arbitrary or palpably incorrect as to warrant judicial interference under Article 226 of the Constitution.

Source reference: para. 10, 11
03

Law Applied

The Court applied the principle that in the absence of any statutory or regulatory provision, a candidate has no legal right to claim re-evaluation.

Source reference: para. 9

It further relied on the doctrine of judicial restraint in academic matters, establishing that evaluation is the exclusive domain of academic experts.

Source reference: para. 10

Under Article 226, judicial review is limited to cases involving mala fides, patent arbitrariness, manifest illegality, or violation of statutory provisions.

Source reference: para. 10

The Court also noted that permitting re-evaluation without statutory backing would undermine the finality of examinations and set a precedent for "floodgates" of litigation.

Source reference: para. 12
04

Reasoning

The Court observed that the petitioner failed to point to any specific regulation that allows for the re-evaluation of answer scripts.

Source reference: para. 9

While the petitioner alleged a "mechanical" marking pattern, the Court determined these were subjective dissatisfactions rather than evidence of mala fides or procedural irregularities.

Source reference: para. 11

The Court emphasized that it cannot act as an appellate body over examiners’ opinions or enter the "academic sphere".

Source reference: para. 11

Furthermore, the petitioner did not provide model answers to prove her responses were objectively correct, leaving her claims of arbitrary marking unsubstantiated.

Source reference: para. 12

The Court reasoned that judicial interference based merely on a student's perception of "quality" would cause administrative chaos.

Source reference: para. 12
05

Holding

The Court answered the issues in the negative, holding that no case for interference was made out under Article 226.

The Court ruled that re-evaluation cannot be claimed as a matter of right without an enabling provision and that the petitioner failed to prove any patent illegality.

Source reference: para. 9, 11

The writ petition was dismissed with no order as to costs.

Source reference: para. 14
Madhya Pradesh High Court

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Smt Arpna PatelvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · May 07, 2026

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