Court says judicial review in exam matters is limited; deletion of defective questions and rejection of objections by subject experts were valid, and repeated questions from another exam did not vitiate the test.
The Punjab and Haryana High Court has dismissed multiple writ petitions challenging the Haryana Public Service Commission’s screening test for recruitment to the post of Assistant Professor (Geography), holding that courts cannot sit in appeal over the opinion of subject experts in academic matters unless an answer key is demonstrably wrong.
Justice Harpreet Singh Brar delivered a common order on several connected petitions, all of which questioned the final answer key, the deletion of certain questions, and the result of the screening test held on 08.06.2025. The petitioners had sought quashing of the final answer key dated 27.06.2025, the announcement dated 03.07.2025 rejecting their objections, and the screening test result declared on 11.07.2025.
The petitioners argued that several answers in the final key were incorrect, citing NCERT and other textbooks. They also claimed that 10 questions had been deleted without justification and that around 30 questions had been repeated from an earlier Bihar Public Service Commission examination, which, according to them, undermined the integrity of the test. Some petitioners further relied on an alleged past practice of the Commission to re-conduct examinations where more than 14% of questions were deleted.
The High Court, however, rejected all these arguments. It noted that objections to the provisional answer key had been placed before subject experts, who finalized the answer key after scrutiny. Even the representations against the final answer key were again considered by experts, who found no reason to alter their earlier view. In the absence of any allegation of mala fides, bias, or lack of competence against the experts, the Court said it could not reassess the correctness of answers by comparing textbooks with expert opinion.
Relying on Supreme Court precedents including Kanpur University v. Samir Gupta, Ran Vijay Singh v. State of Uttar Pradesh, and U.P. Public Service Commission v. Rahul Singh, the Court reiterated that judicial interference is permissible only when an answer key is patently and demonstrably wrong without any inferential reasoning. The Court also upheld the deletion of 10 questions, observing that the deleted questions were uniformly excluded for all candidates and marks were scaled accordingly. A candidate who attempted a deleted question correctly, the Court said, acquires no vested right to marks for it.
On the allegation that questions were repeated from another recruitment agency’s examination, the Court held that mere repetition does not vitiate a competitive exam unless there is material showing prior disclosure, unfair advantage, or malpractice. Since no such material was produced, the challenge on this ground also failed.
The Court concluded that the final answer key, the announcement rejecting objections, and the screening test result did not suffer from any demonstrable error, arbitrariness, or mala fides, and therefore did not violate Articles 14 and 16 of the Constitution. All connected writ petitions were dismissed, and interim orders, if any, were vacated.
Bottom Line:
Recruitment examination - Judicial review of final answer key is extremely limited - Court cannot sit in appeal over opinion of subject experts unless answer key is demonstrably wrong without inferential reasoning - Deletion of ambiguous/wrong questions on expert advice and uniform scaling of marks is valid - Mere repetition of questions from another recruiting agency's examination does not vitiate the test absent proof of prior disclosure, mala fides or unfair advantage.
Statutory provision(s): Articles 14, 16, 226, 227 of the Constitution of India, 1950
Brahampal v. State of Haryana, (Punjab And Haryana) : Law Finder Doc id # 2997215
