Gujarat High CourtAdministrative and Public LawEducation Law

Judicial Review Limited: Benefit of Doubt Must Go to Examining Body in Answer Key Disputes

LAKHAN VANMALIDAS HARIYANIv.GUJARAT SUBORDINATE SERVICE SELECTION BOARD

Judicial Review Limited: Benefit of Doubt Must Go to Examining Body in Answer Key Disputes. LAKHAN VANMALIDAS HARIYANI vs GUJARAT SUBORDINATE SERVICE SELECTION BOARD. Gujarat High Court. LawLens
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In brief

The question

1. Whether the High Court, under Article 226, should interfere with the expert determination of a correct answer in a recruitment examination key.

The court held

The Court answered the issues in the negative, holding that judicial review in recruitment examinations is extremely narrow and the Board's revised final answer key must be presumed correct.

It also directed

The petition was dismissed, and the Court declined the prayer to form an independent committee, stating that the benefit of any doubt belongs to the examination authority. All pending interim stays were vacated, and the request to stay the operation of this judgment was rejected.

01Facts

The petitioners applied for the posts of Research Assistant and Statistical Assistant, Class-III, under Advertisement No. 226/2023-24.

p. 4

Following the written examination on 20.03.2025, the GSSSB published various iterations of provisional and final answer keys.

pp. 4-5

The petitioners, who fell short of the cut-off marks for the SEBC category, challenged the GSSSB’s final answer key regarding Question No. 189: "What is the relationship between demand and price?"

pp. 6-7

The petitioners argued the correct answer is "Direct" based on a 2016 examination key, while the Board maintained the correct answer is "Inverse".

pp. 8-9

During proceedings, an expert committee's opinion was sought by the Board, confirming "Inverse" as the correct answer.

p. 26

02Issues

i.1. Whether the High Court, under Article 226, should interfere with the expert determination of a correct answer in a recruitment examination key.

p. 20

ii.2. Whether the Court should constitute an independent expert committee to resolve perceived ambiguities in examination questions.

p. 3, 24

03Law Applied

The Court primarily applied the principles established in Ran Vijay Singh & Ors. v. State of Uttar Pradesh & Ors. (2018), which mandate that courts must presume the correctness of key answers and, in cases of doubt, the benefit must favor the examining authority.

p. 13, 21

It further relied on Uttar Pradesh Public Service Commission v. Rahul Singh (2018) and Shubham Pal & Others v. Staff Selection Commission (2026), reinforcing that academic matters are best left to academics and that courts should loath directing re-evaluation unless a material error is demonstrated without inferential reasoning.

p. 15, 23

04Reasoning

The Court reasoned that it lacks the specialized expertise to determine the economic relationship between demand and price.

p. 20

It noted that the GSSSB had already undergone a transparent multi-stage objection process, resulting in the revision of 22 questions.

p. 14

Although the petitioners cited a 2016 answer key to support their "Direct relationship" claim, the Court found that when two plausible versions exist, the Law requires the Court to side with the examining body.

pp. 21-22

The Court reviewed the confidential expert opinion and the Chairman’s certificate dated 29.09.2025, which confirmed that "Inverse" was the correct answer (C).

pp. 24-25

Consequently, the Court found no "exceptional circumstances" or manifest error that would justify overstepping its judicial bounds to re-evaluate the technical merits of the question.

pp. 22-26

05Holding

The Court answered the issues in the negative, holding that judicial review in recruitment examinations is extremely narrow and the Board's revised final answer key must be presumed correct.

p. 23, 26

The petition was dismissed, and the Court declined the prayer to form an independent committee, stating that the benefit of any doubt belongs to the examination authority. All pending interim stays were vacated, and the request to stay the operation of this judgment was rejected.

p. 27
Gujarat High Court

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LAKHAN VANMALIDAS HARIYANIvsGUJARAT SUBORDINATE SERVICE SELECTION BOARD

Gujarat High Court · April 28, 2026

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