Students cannot be penalized for institutional clerical errors in examination records.

The petitioner, a regular MBBS student, appeared in the First Professional Examination conducted by the Madhya Pradesh Medical Science University.

In the August 2024 examination, he obtained 30 marks in practical and 7 marks in viva in Anatomy, totalling 37 marks, below the prescribed passing marks.

In the Supplementary and Examinations Examination held in December 2024, the same marks were reflected in his mark-sheet.

Upon inspection of the original practical mark-sheet on 18 February 2025, it was discovered that he had actually secured 50 marks in practical and 10 marks in viva, totalling 60 marks.

Respondent No. 1/College admitted the clerical error and communicated the correct marks to the University authorities through letters dated 10 January 2025 and 18 February 2025.

During the pendency of the writ petition, the Board of Examination (Medical) rejected the request for correction by order dated 3 July 2025.

The petitioner challenged that order under Article 226 of the Constitution, contending that he could not be made to suffer for an error committed by the College and that the rejection order did not disclose adequate reasons.

Whether the University authorities could refuse to correct the petitioner’s MBBS mark-sheet despite the College’s admission that the practical and viva marks had been incorrectly recorded due to a clerical error.

Whether the petitioner could be made to suffer for discrepancies or procedural lapses attributable to the College in uploading and maintaining examination records.

Whether the order dated 3 July 2025 rejecting correction of the marks was arbitrary and liable to be set aside under Article 226 of the Constitution.

The Court exercised its power of judicial review under Article 226 of the Constitution of India to prevent arbitrary administrative action.

It applied the principle that a student should not suffer for mistakes, clerical errors, or procedural lapses committed by an educational institution or examination authority when the student has no control over the relevant process.

The Court further applied the requirement that administrative decisions must be reasoned and cannot be subsequently supported by grounds not contained in the impugned order.

The Court held that where the College itself admitted the error and communicated the correct marks, refusal by the University to rectify the record amounted to arbitrariness.

The Court found that the petitioner had no role in the recording, uploading, or transmission of his practical and viva marks.

Respondent No. 1 expressly admitted that the petitioner had secured 50 marks in practical and 10 marks in viva, totalling 60 marks, and had communicated those marks to the University.

Although the University relied on procedural requirements concerning affidavits, discrepancies in examiner signatures, and differences between marks lists, those grounds were not adequately reflected in the impugned order dated 3 July 2025 and could not justify penalising the petitioner after the event.

Since the error was attributable to the College and the petitioner could not control the examination-record process, denying correction would improperly visit the consequences of institutional negligence upon him.

The Court therefore characterised the refusal to correct the marks as arbitrary and held that the University authorities were duty-bound to rectify the mistake.

Respondent Nos. 2 and 3 were directed to correct the clerical error in the petitioner’s mark-sheet for the MBBS First Professional (Supplementary & Examinations) Examination, December 2024, by recording the correct Anatomy marks claimed by him—50 marks in practical and 10 marks in viva, totalling 60 marks.

The exercise was directed to be completed at the earliest, preferably within 10 days from receipt of the certified copy of the order.