Re-evaluation of competitive examination answers requires proof of a patent, demonstrable error.

The applicant, a general-category candidate in the Engineering Services Examination, 2013, received 633 marks—533 in the written examination and 100 in the personality test. The last selected candidate in the Electronics and Telecommunication Engineering branch received 636 marks.

After obtaining his OMR answer sheet through RTI, the applicant alleged that he had correctly answered Questions 9, 12, 16, 24, 32 and 115 of Paper I, Set A, but had not received marks for them.

He withdrew a writ petition before the Madhya Pradesh High Court with liberty to approach the Tribunal and sought relief in this application.

The UPSC opposed the claim, stating that the answer keys had undergone a three-tier expert validation process and that the examination rules provided no right to re-evaluation.

1. Whether the applicant established a patent or demonstrable error in the answer key or evaluation warranting judicial interference

2. Whether re-evaluation could be directed despite the absence of a provision permitting it, on the basis of the applicant’s materials and cited authorities

In Kanpur University v. Samir Gupta, (1983) 4 SCC 309, judicial relief may be warranted where an answer key is demonstrably incorrect and the correct answer admits of no reasonable doubt.

Ran Vijay Singh v. State of Uttar Pradesh, (2018) 2 SCC 357, requires courts to presume answer keys correct and refrain from re-evaluation, except in exceptional cases involving a patent, demonstrable error; re-evaluation is not routine.

The Tribunal also considered Thangam v. Navamani Ammal, (2024) 4 SCC 247, on non-traverse and deemed admissions, and Naseem Bano v. State of U.P., 1993 Supp (4) SCC 46, on relief granted without disturbing existing appointments; it held both distinguishable in the circumstances.

In the absence of an examination-rule provision for re-evaluation, such a direction ordinarily cannot be made merely on a candidate’s assertion that more marks were due.

The UPSC stated that the answer keys had been prepared and independently approved and revalidated by subject experts at three stages.

The applicant relied on books and internet material to support his answers, but the Tribunal held that this did not establish that the UPSC’s key was demonstrably wrong.

It rejected the argument that the UPSC’s pleadings amounted to an admission under Thangam, explaining that the central question was whether a patent error had been proved.

Nor did Ran Vijay Singh or the Tribunal’s earlier decision in O.A. No. 540 of 2017 require an expert committee or re-evaluation on these facts.

The applicant’s three-mark shortfall and the possibility that additional marks could secure selection did not themselves justify interference; the Tribunal found no evidence of arbitrariness, mala fides or departure from the prescribed procedure.

It dismissed the Original Application as devoid of merit and made no order as to costs.