Review jurisdiction cannot reappreciate academic examination disputes absent an error apparent on the record.

Dr. Tamilarasan challenged the result of his postgraduate examination, alleging, among other things, that internal-assessment marks were not properly accounted for, that some questions were outside the prescribed syllabus, and that his answer scripts were not evaluated in accordance with the applicable rules

By order dated 10 July 2026, the High Court directed re-evaluation by an independent panel and required the authorities to consider awarding 20% marks for internal assessment in theory and practical examinations

AIIMS and the other review petitioners sought review, arguing that the Court had overlooked AIIMS Raipur’s 2017 Academic Committee Resolution, misapplied a circular relating to AIIMS New Delhi, and misunderstood the role of internal assessment under AIIMS Raipur’s rules

Whether the order dated 10 July 2026 disclosed an error apparent on the face of the record by overlooking or misconstruing the applicable AIIMS Raipur examination rules and academic material.

Whether the review petitioners’ grounds warranted reconsideration of the merits of the writ petition in review jurisdiction.

Review jurisdiction is limited to correcting an error apparent on the face of the record or addressing other grounds recognised by law; it cannot be used as an appellate jurisdiction to reappraise evidence or reconsider a decision merely because another view is possible.

The Court relied on Devaraju Pillai v. Sellayya Pillai, (1987) 1 SCC 61; Meera Bhanja v. Nirmala Kumari Choudhury, (1995) 1 SCC 170; Avijit Tea Co. Pvt. Ltd. v. Terai Tea Co., (1996) 10 SCC 174; Lily Thomas v. Union of India, AIR 2000 SC 1650; Akhilesh Yadav v. Vishwanath Chaturvedi, (2013) 2 SCC 1; and Sasi v. Aravindakshan Nair, (2017) 4 SCC 692, for that principle.

The Court held that the earlier order had considered the academic material relevant to internal assessment and the composition of the Board of Examiners.

The objections concerning the applicability of the 2015 circular, interpretation of the 2017 Resolution, internal-assessment marks, and the examination process would require reappraisal of the record and determination of disputed academic issues—not correction of a patent or self-evident error.

The fact that the Court had not accepted the petitioners’ position on question-paper preparation and moderation likewise did not establish an error apparent, particularly since those contentions had been available at the writ hearing.

The order dated 10 July 2026 in WPC No. 1038 of 2024, including its direction for re-evaluation and consideration of internal-assessment marks, remained undisturbed.