Re-evaluation of Answer Scripts Prohibited Absent Statutory Provision or Demonstrated Manifest Error and Malpractice

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

While they secured the required aggregate marks of 200/400 in theory, they were declared "failed" for failing to secure the mandatory minimum of 40 marks in one individual paper

The students sought a writ of mandamus for re-evaluation/third evaluation of the specific failed papers

A learned Single Judge allowed the writ petitions on the grounds of "equity" and "substantial justice," directing a third evaluator to review the scripts

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

Whether the High Court, under Article 226, can direct the re-evaluation of answer scripts in the absence of a statutory provision or in the face of an express prohibition in the regulations

Whether securing the aggregate passing marks constitutes an "exceptional circumstance" or "material error" justifying judicial interference with the examination results

Whether the 15% variation threshold for a third valuation under Regulation 8.4(b) refers to the total marks prescribed for the paper or the marks awarded by the examiners

The Court primarily applied Regulation 8.4 of the Post-Graduate Medical Education Regulations, 2023, which stipulates a twin-threshold for passing: 50% aggregate in theory and a minimum of 40% in each individual paper

Regulation 8.4(c) expressly prohibits re-evaluation after the declaration of results

The Court relied on established precedents including Maharashtra State Board of Secondary and Higher Secondary Education v. Paritosh Bhupeshkumar Sheth

Pramod Kumar Srivastava v. BPSC

and Ran Vijay Singh v. State of U.P.

which collectively hold that in the absence of a specific rule, candidates have no right to claim re-evaluation, and courts should not lean on "sympathy" to override academic regulations.

The Court observed that the evaluation process followed Regulation 8.4(b), where two evaluators assessed each script and their average was taken

Since the difference between the two valuations did not exceed 15% of the "total marks prescribed" (i.e., 15 marks out of 100), the criteria for an automatic third valuation were not met

The Court rejected the students' argument that "equity" should prevail because they met the aggregate criteria, noting that the twin-passing requirement is a standard academic policy and failing to meet one threshold is not a "material error"

The Court further clarified that the 15% variation must be calculated against the maximum marks (100) and not the marks actually awarded, as the plain language of the regulation uses the phrase "total marks prescribed for the paper"

Compassiion or sympathy cannot substitute statutory requirements in academic matters

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