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2025 Supreme(Mad) 2805

IN THE HIGH COURT OF JUDICATURE AT MADRAS 
C.V.KARTHIKEYAN, J.
N.Karthika - Petitioner 
Vs.
State of Tamil Nadu - Respondent 
W.P.No.6881 of 2025 And W.M.P.Nos. 7580, 7581 & 7582 of 2025
Decided On : 28-03-2025

Advocates:
Advocate Appeared:
For the Petitioner: Mr.V.Prakash Senior Counsel for Mr.K.Krishnamoorthy
For the Respondent:Mr. M.Bindran Additional Government Advocate, Mr.J.Ravindran Additional Advocate General assisted by Mr.L.Murugavelu

The court upheld that key answers in examinations are presumed correct unless candidates clearly demonstrate errors; judicial interference in academic matters is limited and should respect expert opinions.

Headnote:(A) Constitution of India - Article 226 - Writ Petition filed for Certiorarified Mandamus - Challenge to provisional list of selected candidates for the post of Assistant Surgeon - Petitioner contended non-inclusion due to scoring 52 marks instead of claimed 59 - Petitioner raised objections against the key answers published for the examination - Court reiterated the principle that key answers are presumed correct unless proven erroneous - Emphasis on the necessity of expert opinion in academic matters and the court's restraint in academic evaluations. (Paras 9-10, 17-43)

(B) Judicial Review - Scope of court's intervention in academic matters - Courts should not substitute their judgment for that of experts, especially in educational assessments, unless there is a clear demonstration of errors in the key answers. (Paras 10, 17, 20)

Table of Content
1. petitioner challenges non-inclusion in the selection list. (Para 1 , 2 , 3)
2. arguments presented regarding the correctness of key answers. (Para 10 , 12 , 13)
3. court's role is limited in reviewing academic evaluations. (Para 11 , 14 , 15 , 16)
4. emphasis on expert evaluations' validity in academic settings. (Para 26 , 27)
5. final decision to dismiss is based on adherence to judicial restraint. (Para 43)

ORDER :

C.V.KARTHIKEYAN, J.

The Writ Petition has been filed in the nature of a Certiorarified Mandamus calling for the records of the provisional list of selected candidates for the post of Assistant Suregon (General) in PSL bearing ref.No.01/MRB/2024, dated 20.02.2025 and to quash the same so far as the non-inclusion of the name of the petitioner is concerned and direct the second respondent to grant 59 marks instead of 52 marks to the petitioner in the exams conducted by the second respondent pursuant to the notification dated 15.03.2024.

2. In the affidavit filed in support of the Writ Petition, it had been contended that the petitioner had applied for the Direct Recruitment to the post of Assistant Surgeon (General) consequent to a notification issued by the second respondent on 15.03.2024. A corrigendum was then issued on 04.02.2025 wherein, the reservations of the posts were announced. It was held out that 192 posts were reserved for Scheduled Caste (General) and 94 posts were reserved for Scheduled Caste (Women). The petitioner belongs to the Scheduled Caste community. The petitioner had attended the computer based examination on 05.01.2025. The key answers were published on 09.01.2025. The respondent had invited objections from the candidates. The petitioner had filed objections for question Nos. 5, 18, 61, 72 and 95. The petitioner claims that she should have obtained 57 marks but was awarded only 52 marks.

3. The petitioner was called for certificate verification by letter dated 06.02.2025. Her certificates were verified on 15.02.2025. The selection list was then published on 20.02.2025. The petitioner was however not selected. The petitioner claimed that the last candidate, who had been selected under the Scheduled Caste (General) category had scored 54 marks. The petitioner has raised her objections with respect to the correctness of the key answers for question Nos. 5, 18, 61, 72 and 95.

4. With respect to question No.5 for which the key answer given was 'a', the petitioner claimed that the question itself is incorrect and therefore she must be given one additional mark.

5. With respect to question No. 18, the key answer given was 'd'. The petitioner claimed that all the four options were correct and therefore, since all the options were correct, she must be given one additional mark.

6. With respect to question No.61, the key answer was given as 'a'. The petitioner claimed that the correct answer is option 'b'.

7. With respect to question No. 72, the key answer given was 'a' but the petitioner claimed that both options 'a' and 'b' are correct and therefore since the petitioner had marked 'b', she should have been given one additional mark.

8. With respect to question No.95, the key answer given was 'a'. The petitioner claimed that the correct answer is option 'c'.

9. Raising these issues, the petitioner had filed the Writ Petition seeking additional marks to be given to her and thereby declaring her to be successful and selected for the post of Assistant Surgeon (General).

10. Mr.V.Prakash, learned Senior Counsel for the petitioner in his arguments took the Court elaborately through the study materials relied on by the petitioner to drive home the point that for question No.5, namely, “Rapid correction of Hypernatremia can cause”, the options given are actually for Rapid correction of Hyponatremia. It is contended that the option related to the Rapid correction of Hyponatremia and not Hypernatremia as contended by the respondents. With respect to question No.18, the learned Senior Counsel again pointed o

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