Repeated Re-evaluation of Competitive Exam Scores Contrary to Recruitment Rules is Impermissible: High Court of Andhra Pradesh - 2026-05-08

A Decade of Litigation Ends: High Court Slams APPSC’s Unauthorized Re-evaluation Practice

In a decisive judgment echoing the necessity of judicial finality, the High Court of Andhra Pradesh at Amaravati has dismissed a petition filed by Pennabadi Amaranath Reddy regarding the evaluation of his Group-I service exam paper from 2008. The Court, presided over by The Honourable Sri Justice Nyapathy Vijay, refused to entertain the applicant's challenge, marking the end of a ten-year legal odyssey that had already been settled by the Supreme Court of India.

The Background: From Exams to Endless Litigation

The dispute originated from the APPSC’s recruitment notification (No. 39/2008) for Group-I services. After the Petitioner failed to qualify for the interview phase—specifically citing a low score in the 'Science and Technology' (Paper-IV)—he launched a campaign of litigation. Over the following decade, the Petitioner moved the Administrative Tribunal, the common High Court at Hyderabad, and eventually the Supreme Court of India, seeking a re-evaluation of his answer scripts. In 2022, the Supreme Court finally dismissed the matter at the admission stage.

Despite this legal finality, the APPSC, following a series of subsequent court mandates to "consider representations," took a highly unusual path. It commissioned two separate expert committees to re-evaluate the Petitioner's Paper-IV. This created a discrepancy where the original score of 49 jumped to 80 in the first committee's report, and between 119 and 123 in the second committee's findings.

Conflicting Arguments: Rules vs. Remediation

The Petitioner argued that the findings of these two expert committees, which confirmed anomalies in the marking, justified his entry into the interview "zone of consideration." He contended that the state had previously agreed to act on these expert findings to provide justice.

Conversely, the State and the APPSC, in their counter-affidavits, admitted that while the committees were formed, the process was fundamentally flawed. They argued that the original recruitment notification and the Commission's Rules of Procedure (Para 11(3) and Rule 3(ix)) explicitly prohibit re-evaluation or recounting. They maintained that to allow re-evaluation now would open the "floodgates" for endless future litigation for past and future recruitment cycles.

Legal Analysis: The sanctity of the Rulebook

Justice Nyapathy Vijay’s judgment heavily relied on established precedents involving the Supreme Court, namely Pramod Kumar Srivastava v. Bihar Public Service Commission , Himachal Pradesh Public Service Commission v. Mukesh Thakur , and Ran Vijay Singh v. State of Uttar Pradesh . These cases unequivocally bar the re-valuation of answer sheets unless specifically provided for by statutes.

The Court noted that by unilaterally appointing committee after committee to review an already-adjudicated matter, the APPSC had effectively undermined the integrity of the recruitment process. The Bench observed that the second expert committee, which significantly inflated the scores, appeared "customized" to benefit the Petitioner.

Key Observations

The judgment provides a stern critique of the administrative handling of this case:

• On the mockery of judicial process: "Though the said judgment was confirmed by the Hon’ble Supreme Court, the APPSC made a mockery of the adjudication by constitutional courts, Rule 3 (ix) of the Rules and the notification itself prohibiting re-valuation, by constituting an expert committee after expert committee."
• On the inconsistencies in marking: "Firstly, when there is substantial variance in revaluations, it would not be safe to rely on such valuations for issuance of a writ of mandamus."
• On the intent of administrative actions: "It is quite apparent that the constitution of two (2) member committee to re-evaluate the Paper-IV of the Petitioner for the third time appears to be customised with an intent to bring the Petitioner within the zone of consideration for appointment."

Final Decision: Costs and Finality

The Court dismissed the writ petition, labeling the repeated re-evaluations as an attempt to bypass established recruitment rules. To discourage litigious persistency that ignores earlier judicial outcomes, the Petitioner was ordered to pay costs of Rs. 50,000 to the Chief Justice Relief Fund.

This ruling serves as a vital reminder for public service commissions: administrative discretion cannot override the explicit, finalized rules of a static notification, nor can it circumvent the finality of decisions rendered by the country's highest courts. Future litigants seeking to re-open historical recruitment issues based on "new" expert committee findings may find little solace in courts following this precedent.