Madhya Pradesh High Court
Education LawAdministrative and Public Law

The Board must verify disputed examination marks against original records before correcting mark-sheets.

Shri Sainath Shiksha Mahavidyalaya Ram Nagar Purasani Gwalior Through Its Principal Shri Munendra Singh Tomar vs Board Of Secondary Education Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: October 05, 20263 MIN READSOURCE JUDGMENT
The Board must verify disputed examination marks against original records before correcting mark-sheets.. Shri Sainath Shiksha Mahavidyalaya Ram Nagar Purasani Gwalior Through Its Principal Shri Munendra Singh Tomar vs Board Of Secondary Education Madhya Pradesh. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner-institution stated that 25 students appeared in the D.El.Ed. Second Year Examination for the 2025–26 session and that it had prepared and forwarded their internal theory assessment and practical/work-experience marks to the Board.

Source reference: p. 1

The published mark-sheets recorded “ABSENT” against the relevant marks. After its representation to the Board remained without effective action, the institution sought correction of the mark-sheets.

Source reference: p. 1

The Board disputed the claim, submitting that internal marks had to be examined under the prescribed submission procedure and that external practical marks were received through the coordinating institution/external examiner; the institution could not unilaterally furnish or alter those external marks.

Source reference: pp. 1–2

The Court also noted prior proceedings concerning rival factions’ management of the institution and operation of its User ID and Password, but confined their relevance to whether the claimed marks had been properly prepared and transmitted.

Source reference: pp. 3–4
02

Issues

Whether the Board should be directed to replace the “ABSENT” entries with the internal assessment marks claimed by the institution without first verifying the relevant examination records.

Source reference: pp. 2–5

Whether the claimed practical/work-experience marks, including external practical marks, required verification through the applicable prescribed channels before any correction could be made.

Source reference: pp. 2–6
03

Law Applied

The petition was brought under Article 226 of the Constitution of India.

Source reference: p. 1

The Court applied the principle that where a dispute turns on factual verification of examination records, an Article 226 court would ordinarily not itself undertake that verification or direct incorporation of particular marks without first allowing the competent authority to examine the original records.

Source reference: p. 5

Marks must be prepared, authenticated, and transmitted through the respective channels prescribed by the Board, and any correction must be supported by original records or other reliable and contemporaneous material.

Source reference: pp. 3–6

No specific statutory provision, Board rule, or precedent was cited by the Court.

Source reference: no citation
04

Reasoning

The competing claims could not be resolved merely by relying on the institution’s asserted marks or the Board’s online entry of “ABSENT.” The Court held that the issue required examination of original examination and institutional records, online and transmission data, receipts, acknowledgments, and other contemporaneous material.

Source reference: pp. 4–5

The prior dispute over institutional management did not require resolution in this petition, but reinforced the need to verify whether marks had actually been prepared and transmitted through the prescribed process.

Source reference: pp. 3–4

External practical marks required separate verification through the external examiner and the prescribed channel; accordingly, the Court declined to award or direct entry of any particular marks itself.

Source reference: pp. 5–7
05

Holding

The Court disposed of the petition without deciding that the marks claimed by the institution were correct.

It directed the institution to submit its claimed internal marks and supporting material within seven days, and the Board to verify the records objectively, including available online and transmission data.

Source reference: pp. 5–6

For external practical marks, the institution must approach the external examiner; the District Education Officer must obtain the examiner’s affidavit and forward it with relevant material to the Board.

Source reference: p. 6

If verification establishes that the marks were duly submitted, the Board must incorporate them and issue revised mark-sheets and corrected results, uploading them where required. The exercise was to be completed, as far as practicable, within four weeks after the institution supplied the requisite material.

Source reference: pp. 6–8
Madhya Pradesh High Court

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Shri Sainath Shiksha Mahavidyalaya Ram Nagar Purasani Gwalior Through Its Principal Shri Munendra Singh TomarvsBoard Of Secondary Education Madhya Pradesh

Madhya Pradesh High Court · October 05, 2026

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