Revaluation cannot modify examination results unless marks vary by more than ten percent.

The petitioner, an LL.M. student, appeared in the LL.M. Second Semester examination conducted in June 2024 and obtained 147 out of 300 marks, resulting in an ATKT status.

He sought revaluation in the subjects of Judicial Process, Drug Edition, Criminal Justice and Human Rights. The University informed him that there was no material change in his marks; however, the revaluation disclosed only minor variations of +4 and +5 marks in one subject and +2 and +1 marks in another.

The petitioner previously approached the High Court in W.P. No. 47531 of 2025. By order dated 12 December 2025, the Court directed the University to consider his application dated 26 November 2025 and provide the necessary information within fifteen days.

Although the University subsequently supplied information regarding the revaluation, it did not issue a modified marksheet. The petitioner therefore sought revision of his result and a declaration that he had passed the LL.M. Second Semester examination.

During the hearing, the University offered to have the answer scripts reassessed by a fourth expert, subject to the petitioner accepting the outcome, but the petitioner declined the proposal.

Whether the petitioner was entitled to revision of his examination result and issuance of a modified marksheet when the variations in marks upon revaluation were below the 10% threshold prescribed under Ordinance No. 5, Point 22(v)?

Whether the Court could direct further reassessment or revaluation by a fourth expert despite the petitioner’s refusal to accept the result of such reassessment?

The Court applied Ordinance No. 5, Point 22(v), which provides that where the marks awarded by either of the two revaluers vary from the original marks by more than 10% of the maximum marks in the paper, the prescribed average of the relevant marks is to be treated as the correct valuation and used for revising the result.

The Court considered Manoj Kumar Jindal v. Ravi Shankar University, Raipur, reported in 1989 AIR (MP) 1, which recognised revaluation as an integral part of the examination process and permitted revision where the governing ordinance so required.

It also considered Shivani Joshi v. Higher Department, W.P. No. 4779 of 2015, where a revised marksheet was directed after a revaluation substantially increased the candidate’s marks.

Conversely, in M.P. Board of Secondary Education v. Ku. Vinita Rupra, 197 SCC OnLine MP 247, the Division Bench held that scrutiny or retotalling does not ordinarily amount to revaluation of the entire answer book and cautioned against orders requiring revaluation contrary to the applicable regulations.

The Court held that the petitioner’s mark variations—+4, +5, +2 and +1—were below the 10% threshold prescribed by Ordinance No. 5, Point 22(v).

Consequently, the regulatory condition for treating the revaluation marks as the basis for revision of the result was not satisfied.

The authorities cited by the petitioner did not justify relief because they were decided in materially different circumstances, including cases involving substantial enhancement of marks or different regulatory provisions.

The Court also noted that the University had offered a further reassessment by a fourth expert, which could have addressed the petitioner’s grievance, but the petitioner refused to accept that course.

In the absence of a violation of the governing ordinance, the Court found no legal basis to compel alteration of the result or issuance of a revised marksheet.

The Court nevertheless left it open to the petitioner to approach the University to avail himself of the proposed reassessment by a fourth expert, which the University was directed to consider sympathetically.