1. Appeals challenging High Court orders regarding the validity and scoring of specific questions in a national law entrance examination. (Para 2 , 9 )
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2025 Supreme(SC) 855
SUPREME COURT OF INDIA
B.R. GAVAI, AUGUSTINE GEORGE MASIH, JJ.
Siddhi Sandeep Ladda – Appellant
Versus
Consortium Of National Law Universities And Another – Respondents
Civil Appeal No. of 2025 (Arising out of SLP(C) No. 12786 of 2025), CIVIL APPEAL NO. OF 2025 (Arising out of SLP(C) No. of 2025)(Diary No. 24223 of 2025)
Decided on : 07-05-2025
Important Points
In academic matters, courts may intervene to rectify improperly framed examination questions affecting candidate assessment and maintain fairness in evaluation processes.
Subject
Public Law - Educational Law
Act Referred
Headnote
(A) Common Law Admission Test (CLAT) - Issues relating to framing of examination questions by the Consortium of National Law Universities and the adequacy of answers - The court emphasized the duty of both State and citizens in environmental protection, correcting the categorization of correct answers in exam questions, and ordered marks to be awarded fairly. (Paras 4, 5, 20, 32, 49, 58)
(B) Examination standards - The court found the questions on the CLAT problematic, asserting the necessity for accurate knowledge requirements in exam questions to uphold the integrity of the testing process. (Paras 24, 50)
(C) Academic diligence - Court expressed concern over the callous manner of question framing and the ensuing impact on candidate outcomes, necessitating judicial intervention to safeguard student interests. (Paras 4, 8)
Facts of the case:
The appeals arose from a High Court judgment concerning the conduct of the CLAT examination, where multiple questions were challenged as improperly framed, leading to calls for correction and reassessment of candidates' answers.
Findings of Court:
The Supreme Court directed changes in the question key, instructed corrections for marks where misclassifications occurred, and clarified that candidates deserved equitable treatment in grading.
Issues: The important issues included the appropriateness of assigned answers in the examination and how to remedy the incorrect assessment.
Ratio Decidendi: The Court held that both the State and citizens hold responsibilities in natural resource preservation, enabling judicial interference when examination frameworks fail to uphold academic integrity.
Result: Appeals disposed of with directives for examination reassessment.
(B) Examination standards - The court found the questions on the CLAT problematic, asserting the necessity for accurate knowledge requirements in exam questions to uphold the integrity of the testing process. (Paras 24, 50)
(C) Academic diligence - Court expressed concern over the callous manner of question framing and the ensuing impact on candidate outcomes, necessitating judicial intervention to safeguard student interests. (Paras 4, 8)
Facts of the case:
The appeals arose from a High Court judgment concerning the conduct of the CLAT examination, where multiple questions were challenged as improperly framed, leading to calls for correction and reassessment of candidates' answers.
Findings of Court:
The Supreme Court directed changes in the question key, instructed corrections for marks where misclassifications occurred, and clarified that candidates deserved equitable treatment in grading.
Issues: The important issues included the appropriateness of assigned answers in the examination and how to remedy the incorrect assessment.
Ratio Decidendi: The Court held that both the State and citizens hold responsibilities in natural resource preservation, enabling judicial interference when examination frameworks fail to uphold academic integrity.
Result: Appeals disposed of with directives for examination reassessment.
Legal Category Hierarchy
Advocates appeared:
For the Petitioner(s): Mr. K K Venugopal, Sr. Adv. Mr. Gopal Sankaranarayanan, Sr. Adv. Mr. Deepak Nargolkar, Sr. Adv. Mr. Soumik Ghosal, AOR Mr. Siddhant Kohli, Adv. Mr. Vishal Sinha, Adv. Ms. Samruthi Gangadhar, Adv. Mr. Gaurav Singh, Adv. Mr. Ashutosh Chaturvedi, Adv. Mr. Dhanesh Relan, Adv. Mr. Krishan Kumar, AOR Mr. Nitin Pal, Adv. Mr. Harsh Kumar Singh, Adv.
For the Respondent(s): Mr. Raj Shekhar Rao, Sr. Adv. Ms. Pritha Srikumar Iyer, AOR Mr. Arun Sri Kumar, Adv. Mr. Shubhansh Thakur, Adv. Mr. Wamic Wasim, Adv. Mr. Anurag, AOR Mr. Hanuman Singh, Adv. Mr. Balbir Singh, Sr. Adv. Mr. Abhishek Anand, Adv. Mr. Rahul Kumar, Adv. Mr. M. P. Devanath, AOR Mr. Sameer Rohatgi, Adv. Mr. Namat Suri, AOR Mr. Kartikey Singh, Adv. Mr. Udhyam Mukherjee, AOR
For the Petitioner(s): Mr. K K Venugopal, Sr. Adv. Mr. Gopal Sankaranarayanan, Sr. Adv. Mr. Deepak Nargolkar, Sr. Adv. Mr. Soumik Ghosal, AOR Mr. Siddhant Kohli, Adv. Mr. Vishal Sinha, Adv. Ms. Samruthi Gangadhar, Adv. Mr. Gaurav Singh, Adv. Mr. Ashutosh Chaturvedi, Adv. Mr. Dhanesh Relan, Adv. Mr. Krishan Kumar, AOR Mr. Nitin Pal, Adv. Mr. Harsh Kumar Singh, Adv.
For the Respondent(s): Mr. Raj Shekhar Rao, Sr. Adv. Ms. Pritha Srikumar Iyer, AOR Mr. Arun Sri Kumar, Adv. Mr. Shubhansh Thakur, Adv. Mr. Wamic Wasim, Adv. Mr. Anurag, AOR Mr. Hanuman Singh, Adv. Mr. Balbir Singh, Sr. Adv. Mr. Abhishek Anand, Adv. Mr. Rahul Kumar, Adv. Mr. M. P. Devanath, AOR Mr. Sameer Rohatgi, Adv. Mr. Namat Suri, AOR Mr. Kartikey Singh, Adv. Mr. Udhyam Mukherjee, AOR
Table of Contents
2. Dispute over whether specific exam questions were logically answerable from provided text or required prior legal knowledge, and whether answer keys were correct. (Para 14 , 18 , 24 , 26 , 35 )
3. The court criticized the casual framing of questions and held that candidates should be able to answer based on logic and provided material without prior legal expertise. (Para 4 , 8 , 28 , 31 , 49 )
4. In objective entrance tests, questions must be answerable through logic and provided material; those requiring excessive external expertise or complex calculations should be deleted. (Para 8 , 28 , 31 , 49 )
5. Modified High Court judgment to award marks for specific options, delete certain questions, and directed the revision of marksheets and commencement of counseling. (Para 22 , 32 , 45 , 50 , 57 , 59 )
6. Who bears the duty to protect natural resources under the Constitution?
Both the State and its citizens have a fundamental duty to preserve and protect natural resources. (Para 17 , 20 )
7. Is an agreement signed by a minor void or voidable based on the provided material?
Such an agreement is voidable, as it remains valid and enforceable unless rejected by the party at a disadvantage. (Para 29 , 30 )
8. Under what circumstances should a question in an objective entrance test be deleted?
A question should be deleted if it requires detailed mathematical analysis not expected in an objective test or if it is logically redundant with other deleted questions. (Para 44 , 49 )
JUDGMENT :
B.R. GAVAI, J.
1. Leave granted.
2. These appeals take exception to the judgment and final order in LPA No.1250 of 2024 dated 23rd April 2025 passed by a Division Bench of the High Court of Delhi at New Delhi (hereinafter referred to as, “High Court”). The Division Bench of the High Court was seized of the Letter Patents Appeals which were filed challenging the judgment and final order dated 20th December 2024 passed by a learned Single Judge of the High Court as well as a batch of Writ Petitions which were filed across various High Courts and which had been transferred to it by this Court.
3. We have heard Shri K.K. Venugopal and Shri Gopal Sankaranarayanan, learned Senior Counsel appearing for the Appellant; Shri Raj Shekhar Rao, learned Senior Counsel appearing for the Consortium of National Law Universities (hereinafter referred to as “Respondent No.1”); Shri Dhanesh Relan, learned counsel appearing for Respondent No.2; Shri Balbir Singh, learned Senior Counsel and other learned counsel appearing for the intervenor(s).
4. At the outset, we must express our deep anguish regarding the callous and casual manner in which the Respondent No.1 has been framing questions for the Common Law Admission Test (hereinafter referred to as, “CLAT”), an examination on the basis of which meritorious candidates get entry into the prestigious National Law Universities across the country.
5. This Court has on a previous occasion by way of a judgment in the case of Disha Panchal and Others v. Union of India through the Secretary and Others , (2018) 17 SCC 278 : 2018 INSC 553, while dealing with a batch of petitions highlighting improper conduct of CLAT, observed thus:
“15. We have dealt with the matter only from the stand point of how best to compensate the candidates who lost valuable time while undergoing test. We must record that we are not at all satisfied with the way the examination was conducted. The body which was given the task of conducting the examination was duty bound to ensure facilities of uninterrupted UPS and generator facility. The record indicates complete inadequacy on that point. We therefore direct Union of India in the Ministry of Human Resources and Development to appoint a Committee to look into the matter and take appropriate remedial measures including penal action, if any, against the body which was entrusted with the task. The Committee so constituted shall also look into the aspect of having completely satisfactory arrangements in future so that no such instances are repeated or reoccur in coming years. We must also observe that the idea of entrusting the task of monitoring the conduct of entire examination to different Law Universities every year also needs to be re-visited. The agreement with the examination conducting body, which was placed on record indicates that as against the amount made over to such examination conducting body, the fees charged from the candidates are far in excess. The committee shall bestow consideration to all these aspects after having inputs from such sources as it may deem appropriate including Bar Council of India and make a detailed report to this Court within three months from today.” (emphasis added)
6. It can thus be seen that this Court has constituted a committee to inter-alia look into the shortcomings in the conduct of CLAT. It can further be seen that this Court has specifically observed that the idea of entrusting the task of monitoring the conduct of the entire examination to different Law Universities every year also needs to be re-visited.
7. We are informed that though the said committee’s report has been received, it has been placed before a Bench of this Court seized of WP(C) No. 600 of 2015 titled as “ Shamnad Basheer v. Union of India and Others ”. The sole petitioner in the said matter, however, has passed away. We shall, accordingly, after dealing with the present matter pass an appropriate order in this regard.
8. Insofar as the present appeals are concerned,
