Re-evaluation of Answer Scripts Prohibited Absent Regulatory Provision or Manifest Error Despite Failure by Single Mark

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

In their 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, their papers were evaluated by two examiners, and the average was taken as the final result.

The students sought re-evaluation, which is expressly prohibited by Regulation 8.4(c).

A Learned Single Judge allowed their writ petitions, directing a third evaluation on the grounds of "substantial justice" and "equity" because the students had passed in the aggregate.

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

Whether the Court can direct re-evaluation of answer scripts on grounds of equity or sympathy when the governing statutory regulations expressly prohibit such re-evaluation.

Whether the "15% difference" threshold for a third valuation under Regulation 8.4(b) should be calculated based on the marks awarded or the total marks prescribed for the paper.

The Court applied Regulation 8.4 of the Post-Graduate Medical Education Regulations, 2023, which stipulates a twin requirement for passing: 50% aggregate and 40% minimum in each paper, while sub-clause (c) strictly prohibits re-evaluation.

It relied on the Supreme Court precedents in Maharashtra State Board of Secondary and Higher Secondary Education v. Paritosh Bhupeshkumar Sheth, establishing that courts cannot order re-evaluation absent a specific rule.

Ran Vijay Singh v. State of Uttar Pradesh, which held that re-evaluation can only be permitted in "rare or exceptional cases" of patent material error demonstrated without inferential reasoning.

Furthermore, Dr. NTR University of Health Sciences v. Dr. Yerra Thrinadh was cited to affirm that sympathy or compassion plays no role in directing re-evaluation.

The Court observed that the criteria for passing—both aggregate and individual paper thresholds—are well-defined and standard academic requirements.

It found that the students failed to demonstrate any malpractice, procedural irregularity, or manifest error in the evaluation process; the mere fact of failing by a small margin despite a high aggregate does not constitute an "exceptional circumstance".

Regarding the calculation of the 15% variation, the Court noted that while pegging the variation to the "total marks prescribed" (i.e., 100) might lead to mathematical anomalies where low marks are concerned, the plain language of Regulation 8.4(b) is unambiguous and refers to the maximum marks of the paper.

Consequently, the Court held it could not substitute its own interpretation for the clear letter of the law.

On the second issue, it held that "15% of total marks prescribed" means 15% of the maximum marks (100).

The Writ Appeals were allowed, the impugned orders of the Learned Single Judge were set aside, and the original results declaring the candidates "failed" were upheld.