Re-evaluation of Answer Scripts Prohibited Absent Express Statutory Provision or Evidence of Manifest Error

The respondents (original writ petitioners) were Post-Graduate medical students who appeared for examinations in September 2025 under the Rajiv Gandhi University of Health Sciences.

While they secured an aggregate of 50% or more marks across four theory papers, they failed to obtain the mandatory minimum of 40 marks in one specific paper.

Under Regulation 8.4 of the Post-Graduate Medical Education Regulations, 2023, their papers were evaluated by two evaluators, and the average was taken.

The students approached the High Court seeking re-evaluation.

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

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

1. Whether the Court can direct re-evaluation of answer scripts in the absence of a provision for the same in the governing Regulations and where such re-evaluation is expressly prohibited.

2. Whether the "15% difference" threshold for a third evaluation under Regulation 8.4(b) refers to 15% of the total marks prescribed for the paper or 15% of the marks actually awarded.

The Court applied Regulation 8.4 of the Post-Graduate Medical Education Regulations, 2023, which stipulates a dual evaluation system and expressly prohibits re-evaluation under Clause (c).

It relied on the Supreme Court precedents in *Maharashtra State Board of Secondary and Higher Secondary Education v. Paritosh Bhupeshkumar Sheth*, *Pramod Kumar Srivastava v. Chairman, Bihar Public Service Commission*, and *Ran Vijay Singh v. State of Uttar Pradesh*, which establish that in the absence of statutory provisions, candidates have no right to claim re-evaluation unless a manifest material error is demonstrated without inferential reasoning.

Furthermore, *Dr. NTR University of Health Sciences v. Dr. Yerra Thrinadh* was cited to affirm that sympathy or equity cannot override statutory examination rules.

The Court reasoned that Regulation 8.4(c) contains an explicit bar on re-evaluation, which the Single Judge overlooked by invoking "equity".

The Court found no allegations of malpractice, procedural irregularity, or examiner incompetence that would warrant an exception to the general rule against judicial interference in academic assessments.

Regarding the students' aggregate marks, the Court held that meeting the 50% aggregate threshold does not exempt a candidate from the distinct mandatory requirement of securing 40% in each individual paper; these are twin conditions that must both be satisfied.

Addressing the interpretation of Regulation 8.4(b), the Court held that the phrase "15% of the total marks prescribed for the paper" unambiguously refers to the maximum marks (100) and not the marks awarded, meaning a third evaluation is only triggered by a difference of 15 marks or more.

It held that the Court cannot grant re-evaluation on grounds of sympathy or aggregate performance when the Regulations expressly prohibit it.

The prayer for a third evaluator was rejected as the difference between the first two evaluations did not exceed the 15-mark threshold (15% of 100) stipulated in Regulation 8.4(b).

All connected writ appeals were allowed.