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2025 Supreme(Raj) 2357

HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR
PUSHPENDRA SINGH BHATI, BALJINDER SINGH SANDHU, JJ.
Ashish Kumar Sharma, S/o Sh. Vinod Kumar Sharma - Appellant
Versus
Rajasthan Public Service Commission, Through Its Secretary, Ghooghra Ghati, Jaipur Road, Ajmer - Respondent
D.B. Special Appeal Writ No. 232 of 2024, D.B. Special Appeal Writ No. 710 of 2022, D.B. Special Appeal Writ No. 711 of 2022, D.B. Special Appeal Writ No. 718 of 2022, D.B. Special Appeal Writ No. 853 of 2022, D.B. Special Appeal Writ No. 865 of 2022, D.B. Special Appeal Writ No. 887 of 2022, D.B. Special Appeal Writ No. 1268 of 2022, 
Decided On : 21-11-2025

Advocates Appeared:
For the Appellant : Mr. R.K. Mathur, Sr. Adv. Assisted By Mr. Aditya Vikram Singh Panwar, Mr. Sushil Pujari, Mr. Manish Parihar, Mr. Ashwini Kumar Jaiman With Mr. Keshav Parashar, Mr. Moin Khan, Mr. Ashish Kabra, Mr. Raghunandan Sharma With Mr. Arvind Kumar, Arora Mr. Abhinav Srivastava, Ms. Kritika Rajawat, Mr. Ayush Bishnoi
For the Respondent: Mr. B.S. Chhaba, Aag Assisted By Mr. Avinash Chaudhary, Mr. Hardik Singh, Mr. M.F. Baig For Rpsc Assisted By Mr. Govind Gupta

The scaling method used in examinations involving different optional subjects ensures equitable assessment and is legally supported, even if not explicitly mentioned in the rules.

Headnote:(A) Rajasthan Forest Service Rules, 1962; Rajasthan Forest Subordinate Service Rules, 2015 - Recruitment process for Assistant Conservator of Forest and Forest Range Officer - Adoption of scaling method for evaluation of marks from optional subjects - Scaling recognized as appropriate to ensure fairness among candidates selecting different subjects. (Paras 1-2, 12-14, 30-32)

(B) Legal Concept - Scaling in examinations - A method to achieve uniformity in evaluation when candidates select diverse subjects and face varying difficulty levels - Recognized by the Supreme Court as a fair approach to assess inter se merit. (Paras 18-20, 27-29)

Facts of the case:
Recruitment advertisement issued for 99 posts of Assistant Conservator of Forest increased to 115 and 70 posts of Forest Range Officer Grade-1 increased to 127. Writ petitions were filed challenging the legality of scaling method applied in the examination results; the Single Judge dismissed the petitions, leading to these appeals.

Findings of Court:
The scaling method was justified as it ensured fairness in evaluation particularly for optional subjects, and the process followed by the RPSC was rooted in expert recommendations.

Issues: The main questions were the permissible methods for mark evaluation under the applicable rules and the justification of the scaling method previously sanctioned by judicial precedents.

Ratio Decidendi: The Court ruled that the RPSC's scaling methodology was appropriate in the context of varying subject difficulties, underscoring that scaling is essential for equitable assessment in multi-subject examinations.

Result: Appeals dismissed.

Table of Content
1. recruitment process and advertisement details. (Para 1 , 2 , 3 , 4)
2. challenges to scaling method and alleged irrationality. (Para 5 , 6 , 7 , 8)
3. review of examination rules and procedure for merit assessment. (Para 9 , 10 , 11 , 12 , 13)
4. judicial scrutiny on scaling methodology and its applicability. (Para 14 , 15 , 16 , 17 , 18 , 19)
5. validation of scaling methods based on expert opinions. (Para 20 , 21 , 22 , 23 , 24)
6. fundamentals of scaling in varied subject examinations. (Para 25 , 26 , 27 , 28 , 29)
7. discussions on procedural fairness and legal backing for scaling. (Para 30 , 31 , 32 , 33 , 34)
8. conclusion on the validity and legality of the scaling process. (Para 35 , 36 , 37 , 38 , 39)
9. final decision and dismissal of appeals. (Para 40 , 41 , 42)

JUDGMENT :

BALJINDER SINGH SANDHU, J.

1. The brief facts giving rise to the present special appeals are that the Rajasthan Public Service Commission (hereafter referred to as RPSC/Commission) issued an advertisement dated 04-04-2018 publishing 99 posts of the Assistant Conservator of Forest under the Rajasthan Forest Service Rules 1962 and 70 posts for Forest Range Officer Grade-1 under the Rajasthan Forest Subordinate Service, Rules 2015 (hereinafter referred to as the “Rules of 1962” and the “Rules of 2015”). After issuing the corrigendum, the total seats were increased to 115 for the post of Assistant Conservator of Forest and to 127 for the post of Forest Officer Grade-I.

2. The recruitment process was to be undertaken in two phases, written test and interview. The syllabus for the competitive examination was provided in the advertisement. As per the scheme of the written examination, the same was divided into two parts. The first one was the compulsory subjects of General Knowledge and General English carrying hundred marks each. The second part consisted of the optional subjects. Out of 20 subjects provided in the syllabus, the candidates were to select any two subjects of their choice and the same carried 200 marks each. As per the note, the candidates were not allowed to take more than one subject in the five groups provided in the syllabus. The written examination was objective in nature and the same was conducted from 18-02-2021 to 26-02-2021 in various subjects, and the result of the said examination was declared on 09-12-2021.

3. Before declaration of the result, the respondent-RPSC in its full commission meeting dated 01-10-2021, took a decision to adopt the scaling and constituted a special committee for recommending the procedure of scaling or otherwise to be adopted for declaration of the results. The meeting of the committee was held on 12-11-2021 as well as on 04-12-2021. The Committee considered the scheme of the examination as well as the compulsory and the optional papers, that the candidates were to undertake. The committee after considering the scheme of the syllabus, resolved not to adopt any scaling in the compulsory papers, which was to be undertaken by all the candidates. Regarding the optional papers, the committee resolved, after taking into consideration the difficulty level of each of the question papers, the mean and the standard deviation of raw scores obtained in paper, to implement the method of scaling of raw scores in optional paper, as per the formula used by the RPSC. The tables prepared on the difficulty index of each optional paper, as well as on the mean and standard deviation of the raw scores obtained by the candidates in the optional papers, were considered. Only after technically examining the things, the scaling formula was adopted.

4. The RPSC declared the result after scaling of the marks and 871 candidates who obtained the qualifying marks were called for the interview. It is an admitted position that after the interviews were conducted, the appointments have been granted and all the vacancies have been filled during the pendency of the present petitions.

5. Aggrieved against the action of the respondent-







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