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2026 Supreme(Del) 317

IN THE HIGH COURT OF DELHI AT NEW DELHI
ANIL KSHETARPAL, AMIT MAHAJAN, JJ.
 
Hanumant Lal Patel & Ors. – Appellants
Versus
Union Of India & Ors. – Respondents
W.P.(C) 4354 of 2025
Decided On : 03-02-2026
 

Advocates Appeared:
For the Appellants : Mr. Ritesh Kumar, Adv.
For the Respondents: Mr Balendu Shekhar CGSC with Mr Krishna Chaitanya, Mr Rajkumar Maurya and Mr Divyansh Singh Dev, Advs., Mr. Ravinder Agarwal, Mr. Manish Kumar Singh & Mr. Vasu Agarwal Adv.

Judicial review in academic matters is limited; courts should not interfere unless there is clear evidence of illegality or arbitrary decision-making by examination authorities.

Headnote:(A) Constitution of India - Articles 226 and 227 - Judicial review - The petition was filed challenging the dismissal of the application regarding out-of-syllabus questions in Civil Services Examination 2023 - The court cannot interfere in academic matters without evidence of illegality or arbitrariness. (Paras 1, 26)

(B) Scope of Judicial Review - The court emphasized that it will not substitute its views for that of subject experts in competitive examinations unless misconduct is evident. (Paras 25, 30)

(C) Requisite for Judicial Relief - Nothing was presented to demonstrate the questioned items were beyond the syllabus or created an unlevel playing field. (Paras 14, 36)

Facts of the case:
The appellants, unsuccessful candidates, claimed 11 questions in Paper-II were out of the prescribed syllabus. Their application to the CAT was dismissed, holding no grounds for interference. (Paras 1, 10)

Findings of Court:
The Expert Committee found all questions in Paper-II conformed to the prescribed syllabus, thus refuting allegations of unfairness. (Paras 30, 34)

Issues: Whether the questions in examination exceeded the prescribed syllabus and if the applicants had grounds for judicial intervention. (Paras 3, 14)

Ratio Decidendi: The court ruled that the evaluation process and question formulation fall within expert jurisdiction; mere disagreement does not justify judicial review. (Paras 32, 36)

Result: Petition dismissed.

Table of Content
1. challenging examination results for alleged irregularities (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10)
2. arguments concerning out-of-syllabus questions (Para 12 , 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20)
3. finality of prior judgments impacting current proceedings (Para 24 , 34)
4. judicial review limitations on examination processes (Para 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 35 , 36)
5. dismissal of the petition based on findings (Para 39 , 40)

JUDGMENT :

AMIT MAHAJAN, J.

1. The present writ petition has been filed under Articles 226 and 227 of the Constitution of India, assailing the order dated 28.11.2024 passed by the learned Central Administrative Tribunal, Principal Bench, New Delhi, (hereinafter ‘CAT’) whereby the O.A. No. 3109 of 2024, preferred by the Petitioners/Civil Services Aspirants challenging certain questions of the Civil Services (Preliminary) Examination, 2023, particularly Paper-II (CSAT), came to be dismissed.

2. The Petitioners, being unsuccessful candidates in the Civil Services (Preliminary) Examination 2023, seek interference with the impugned order on the premise that about 11 questions in Paper-II (CSAT) were allegedly beyond the prescribed syllabus, thereby vitiating the examination and selection process.

3. Succinctly stated, the quintessential facets leading up to the present dispute are that, the Respondent No. 3/Union Public Service Commission (hereinafter ‘UPSC’) conducts the Civil Services Examination annually for recruitment to various Group ‘A’ and Group ‘B’ services under the Union of India, through a three-stage process consisting of the Preliminary Examination, the Main Examination, and the Personality Test.

4. The Civil Services Examination Rules, 2023 for Civil Services Examination, 2023 came to be published by the Department of Personnel & training (hereinafter ‘DoPT’)/Respondent No.1 herein on 01.02.2023.

5. The details of the syllabi for the said examination were set out in Part B of Section III of the aforesaid rules and the candidates had been advised to go through the Syllabus so published in that Section for the Preliminary Examination and the Main Examination. With respect to Paper-II of the Preliminary Exam the syllabus was provided as “Basic numeracy (numbers and their relations, orders of magnitude, etc.) (Class X level), Data interpretation (charts, graphs, tables, data sufficiency etc. — Class X level)”

6. Admittedly, the Civil Services (Preliminary) Examination, 2023 was conducted and the Petitioners appeared in the said examination on 28.05.2023, including Paper-II (CSAT). The results of the Preliminary Examination were declared on 12.06.2023. Thereafter, the Civil Services (Main) Examination was conducted and its results were declared on 08.12.2023. The Personality Tests followed, culminating in the declaration of the final results on 16.04.2024.

7. The Respondent No. 3/UPSC had also opened a grievance redressal portal on its official website from 29.05.2023 to 04.06.2023. In response, the Petitioners, having failed to qualify the Preliminary Examination, submitted their grievances through the said portal, highlighting the inclusion of out-of-syllabus questions.

8. Thereafter, the Petitioners approached the Hon’ble Supreme Court by way of a petition filed under Article 32 of the Constitution of India, which was dismissed and with liberty to the Petitioners to approach the concerned High Court.

9. The Petitioners then approached this Court, by way of a writ petition bearing W.P. (C) No. 14426/2023 seeking directions to the Respondent No. 3/UPSC to verify the disputed questions, prepare a revised merit list, conduct the Mains Examination for candidates who would become eligible pursuant thereto, and in the alternative, grant of compensatory attempts or age relaxation. Vide order dated 19.07.2024, the writ was transferred to the learned CAT opining that the same was the first forum of instance.

10. Thereafter, the writ petition was renumbered as the O.A. No. 310

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