Madhya Pradesh High Court

Revaluation of answer scripts cannot be claimed as a right absent statutory provision, except in rare cases of grave injustice.

Pallavi Sainik v. Board of Secondary Education [2026:MPHC-GWL:8735]

Madhya Pradesh High Court2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a student who appeared in the Higher Secondary School Certificate Examination (10+2) in 2017, challenged her marks in the subject of Hindi.

Source reference: p.3

Although she passed in the First Division, she alleged that the examiner awarded lesser marks for questions 9, 10, 11, 12, 14, and 15 despite correct answers.

Source reference: p.4

She sought a writ of mandamus directing the respondent to get her answer book verified by an expert and to award correct marks.

Source reference: p.2

The respondent-Board refused the request for revaluation, citing the absence of such a provision in its statutory regulations.

Source reference: p.5-6
02

Issues

1. Whether a candidate has a legal right to seek revaluation of an answer script in the absence of a specific statutory provision or regulation permitting the same.

Source reference: p.9-10

2. Whether the Court, under Article 226 of the Constitution, should interfere with the subjective evaluation of descriptive/subjective answers by an academic examiner.

Source reference: p.12-14
03

Law Applied

The Court applied Regulation 119 of the Regulations of the Board of Secondary Education, M.P., which permits only retotaling/verification and expressly excludes revaluation.

Source reference: p.6, 13

It relied on the Supreme Court precedent in Ran Vijay Singh v. State of Uttar Pradesh, which established that courts should not scrutinize answer sheets as they lack expertise and must presume the correctness of evaluation.

Source reference: p.9

It further cited High Court of Tripura v. Tirtha Sarathi Mukherjee, holding that revaluation in the absence of a provision is permissible only in "rare and exceptional" cases of manifest error.

Source reference: p.10

It further cited Ankur Sharma v. M.P. Medical Science University, which limited such interference to cases of gross discrepancy or injustice.

Source reference: p.11
04

Reasoning

The Court reasoned that since Regulation 119 specifically excludes revaluation, the petitioner cannot claim it as a matter of right.

Source reference: p.13

The Court noted that the Hindi paper consisted of subjective, descriptive answers rather than objective questions.

Source reference: p.12

The marks awarded for such answers represent the "subjective satisfaction of the expert," which is not ordinarily open to judicial review unless "manifest illegality or palpable perversity" is shown.

Source reference: p.12, 15

The Court found that the petitioner failed to demonstrate any such rare or exceptional circumstance that would justify invoking discretionary powers under Article 226, characterizing the petition as an attempt to call for a "roving inquiry."

Source reference: p.15
05

Holding

The Court answered the issues in the negative, holding that there is no legal right to revaluation without a statutory basis and that the Court will not substitute its judgment for that of an academic expert in subjective evaluations.

The Writ Petition was dismissed as being without merit.

Source reference: p.16

No order as to costs was made.

Source reference: p.18
Madhya Pradesh High Court

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Pallavi Sainik v. Board of Secondary Education [2026:MPHC-GWL:8735]

Madhya Pradesh High Court

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