Re-evaluation of PG Medical Answer Scripts Prohibited Absent Manifest Error or Specific Regulatory Provision

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

In the examinations held in September 2025, 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.

They sought re-evaluation of their answer scripts despite Regulation 8.4(c) of the Post-Graduate Medical Education Regulations, 2023, which expressly prohibits re-evaluation.

The Learned Single Judge allowed their writ petitions on the grounds of "equity" and "substantial justice," directing a third valuation.

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

1. Whether the Court can direct re-evaluation of answer scripts in the absence of a statutory provision or in the face of an express legal prohibition.

2. Whether securing an aggregate passing mark while failing a single subject constitutes an "exceptional circumstance" warranting judicial interference on grounds of equity.

3. 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 actually awarded by evaluators.

The Court applied Regulation 8.4 of the Post-Graduate Medical Education Regulations, 2023, which mandates two valuations and prohibits re-evaluation after the declaration of results.

It relied on the Supreme Court precedent in Maharashtra State Board of Secondary and Higher Secondary Education v. Paritosh Bhupeshkumar Sheth, which established that students have no right to re-evaluation unless the statute specifically provides for it.

The Court further applied the "material error" exception from Ran Vijay Singh v. State of Uttar Pradesh, noting that re-evaluation can only be ordered in rare cases of demonstrable manifest error without inferential reasoning.

It reiterated from Dr. NTR University of Health Sciences v. Dr. Yerra Thrinadh that sympathy or compassion plays no role in such legal determinations.

The High Court found that the criteria for passing—50% aggregate and 40% per paper—are well-defined and the students failed to meet the twin conditions.

The Court observed that there were no allegations of malpractice, procedural irregularity, or evaluator incompetence; therefore, no "manifest error" existed to trigger the Ran Vijay Singh exception.

It critiqued the Single Judge’s reliance on "equity," holding that judicial interference is impermissible when a regulation (8.4(c)) expressly prohibits re-evaluation.

Regarding the 15% variation rule, the Court rejected the students' interpretation that it should be calculated based on marks obtained; it held that "total marks prescribed for the paper" unambiguously means the maximum marks (100), and thus a third valuation is only triggered by a difference exceeding 15 absolute marks.

The Court held that in the absence of a statutory right and in the presence of an express prohibition, no mandamus for re-evaluation can be issued solely on the grounds of equity.

The prayer for third valuation was rejected as the variation in marks did not exceed 15% of the total marks prescribed.

All writ petitions filed by the students were effectively dismissed.