CAT Dismisses Pleas Against SSC CGLE 2024 Results, Cites Limited Judicial Review Despite "Callous" Approach

New Delhi: The Central Administrative Tribunal (CAT), Principal Bench, has dismissed a batch of Original Applications (OAs), led by Abhi Naitan vs. Staff Selection Commission (SSC) , challenging the results of the Combined Graduate Level Examination (CGLE) 2024. While expressing "deep dismay and disappointment" at the SSC's handling of the examination, particularly the award of grace marks for numerous flawed questions, the Tribunal ultimately declined to interfere, citing its limited scope of judicial review in academic matters involving subjects outside its expertise.

The decision was delivered by Hon’ble Ms. Harvinder Kaur Oberoi, Member (J), and Hon’ble Dr. Sumeet Jerath, Member (A), who pronounced a common order for O.A. No. 1102/2025 and four other similar OAs.

Case Overview

The applicants, who had qualified Tier-I of the CGLE 2024, were aggrieved by their exclusion from the final result of the Tier-II examination, declared on March 12/13, 2025. They sought to quash the result to the extent of their exclusion, inclusion in the final selection list, or alternatively, the quashing of Paper-I Session-I of the Tier-II exam with a directive for a re-examination.

The core dispute revolved around alleged arbitrariness in the normalization process, the awarding of bonus marks for a significant number of questions (19 across two exam dates) deemed invalid post-examination, and the publication of the final answer key after the declaration of the results.

Applicants' Contentions

The applicants, represented by Advocate Mr. Shree Prakash Sinha and Mr. Abhinav Hansaraman , argued vehemently that: * Normalization Flaws: The normalization process led to an arbitrary and excessive variation in marks (20 to 62 marks more for some candidates with lower raw scores), disadvantaging meritorious candidates. * Unfair Bonus Marks: The declaration of 19 questions (9 from the exam on 18.01.2025 and 10 from 20.01.2025) as erroneous and the subsequent award of equal marks to all candidates, including those who answered wrongly or left them unattempted, was unjust. They contended this nullified the advantage of those who answered correctly and unfairly benefited others. For instance, a candidate who answered wrongly would gain 7 marks per question (3 for the awarded mark and avoiding a -4 penalty). * Procedural Irregularity: The final answer key was published on March 18, 2025, after the results were declared on March 12/13, 2025, allegedly violating the SSC's own examination scheme (Para 13.3 of the advertisement) which implied finalization of answer keys before result declaration. * Legitimate Expectation: Applicants had a legitimate expectation to be included in the merit list based on their performance. * Judicial Precedent: They cited several judgments, including Guru Nanak Dev University v. Saumil Garg , to argue that courts can intervene when the examination process is flawed or palpably incorrect.

Respondents' Defense

The Staff Selection Commission (SSC) and the Department of Personnel and Training (DoPT), represented by advocates including Mr. Gyanendra Singh , countered that:

* Established Procedure: The process of publishing tentative answer keys, inviting objections, scrutinizing them by Subject Matter Experts (SMEs), and then finalizing keys (even if after results) was consistently followed for both Tier-I and Tier-II. Applicants did not challenge this in Tier-I.

* Normalization Formula: A uniform normalization formula was applied. Normalized scores differ from raw scores based on relative performance across shifts.

* Expert Opinion: Full marks were awarded for erroneous questions based on SME recommendations, a standard practice.

* No Re-evaluation: The examination rules (Para 13.6) explicitly prohibit re-evaluation or re-checking.

* Limited Judicial Review: They relied on precedents like Mahesh Kumar vs. SSC to argue that courts lack expertise in academic evaluation and should not interfere, especially when there's no provision for re-evaluation. The benefit of the doubt should go to the examining authority.

Tribunal's Analysis and Conclusion

The Tribunal meticulously examined the arguments and the cited precedents regarding the scope of judicial review in examination matters. It acknowledged a line of judgments favoring judicial review in cases of manifest error but distinguished the present case.

Key excerpts from the judgment highlight the Tribunal's reasoning:

> "We have observed that in both these cases [CLAT-related judgments], the Hon’ble Courts did exercise their power of ‘judicial review’ in the questions set and their evaluation... as the Lordships were Legal Eagles and had abundant knowledge of the Science, Art and Craft of Law. They could thus easily override the knowledge, skills and views of the experts... These cases are clearly distinguishable from the facts and circumstances of the instant OA where the questions set are not from the field of Law but questions set on General Knowledge drawing from diverse fields like Mathematics, English, History, Logical Reasoning, Chemistry, General Science etc. The Tribunal is not an expert in these subjects..."

Relying on judgments like Mahesh Kumar vs. SSC (upheld by the Supreme Court), which state that "academic matters are best left to the academics" and "Courts should presume the correctness of the evaluation," the Tribunal concluded it was "not inclined to interfere in the matter at all."

However, the Tribunal did not mince words in criticizing the SSC:

> "However, the callous and casual attitude of the Experts of the SSC have floored, flummoxed and flabbergasted us on the sheer scale of 22 questions [incorrectly stated as 22 in para 13, actual count 19 based on para 3 and 4.9] where grace marks were awarded to all the candidates; even those who had not even attempted the vague/disputed questions or given wrong answers to the doubtful questions. Also we are puzzled and perplexed that while the ‘tentative answer key’ was vetted and endorsed by the Experts of SSC; later the Experts after getting feedback from the applicants across the County had to change their views not in just one or two but twenty two (19) questions. We are, therefore, of the opinion that SSC should have wiser and more erudite Experts on their panel who set totally unambiguous questions which have clear cut answers in future."

The Tribunal also noted that the issue of the final answer key being released after the result publication was dropped by the applicants' counsel during final arguments, as the same procedure was followed in Tier-I, which they had not challenged at that stage.

Final Decision and Implications

The Tribunal dismissed all the OAs without costs. While upholding the SSC's actions procedurally, the judgment serves as a strong critique of the examination body's question-setting and evaluation standards.

> "As we part, we would express our deep dismay and disappointment on the ‘unlevel playing field’ created by SSC by giving grace marks to candidates who had not even attempted the ambiguous and doubtful questions or gave the wrong answers to these ambiguous questions. We are however sanguine that SSC would be more circumspect and cautious in future and that their attitude will not remain casual, cavalier and callous always."

The decision underscores the judiciary's general reluctance to step into the shoes of academic experts for subjects beyond its domain, even when faced with apparent shortcomings in the examination process. It places the onus on examining bodies like the SSC to improve their internal mechanisms to ensure fairness and accuracy.