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2025 Supreme(Mad) 4494

IN THE HIGH COURT OF JUDICATURE AT MADRAS
J. NISHA BANU, M. JOTHIRAMAN, JJ.
S. Sai Priya D/o Selvam G. - Appellant
Versus
Union of India Represented by its Secretary, New Delhi - Respondent
W.A. No. 1707 of 2025, C.M.P. No. 12937 of 2025
Decided On : 03-07-2025

Advocates:
Advocate Appeared:
For the Appellant : T. Saikrishnan
For the Respondents: A.R.L. Sundaresan, M. Sathyan, Sunitha Kumar, Subharanjani Anand

Brief power outages during examinations, if adequately managed, do not warrant re-examination unless they substantially disrupt the exam process or show malice.

Headnote:(A) Constitution of India - Right to Education - NEET (UG) Examination Guidelines - Power outage during examination - Petitioners sought for re-examination due to a brief power outage, asserting that it disrupted exam conditions; however, the court upheld the conclusion by National Testing Agency (NTA) that conditions remained adequate for examining candidates. (Paras 5, 9, 14)

(B) During examination administration, minor issues such as power outages need to be weighed against the integrity and fairness of the examination process, particularly for a large-scale national examination. (Paras 10, 14)

Facts of the case:
Appellants claimed that a power outage during the NEET UG Examination affected exam conditions at multiple centres and sought re-examination; assessments showed candidates were able to complete their exams without disruption.

Findings of Court:
Examination was conducted smoothly despite a power outage; candidates’ performance data indicated no adverse impact due to the nature of the outage; integrity of the examination upheld.

Issues: The court addressed whether the power outage significantly disrupted the examination conditions warranting a re-examination for the affected candidates.

Ratio Decidendi: The court affirmed the NTA's findings that despite a brief power outage, the examination conditions were sufficiently maintained, rejecting calls for re-examination on grounds that did not demonstrate material disruption or malice.

Result: Writ appeal dismissed.

Table of Content
1. grounds for appeal based on exam conditions. (Para 1 , 2 , 3)
2. arguments on exam disruptions and need for re-examination. (Para 4 , 5)
3. court's order for evidence and examination review. (Para 6 , 7 , 10)
4. examination integrity upheld; no grounds for re-exam. (Para 8 , 9)
5. judicial restraint in administrative decisions. (Para 11 , 12 , 13 , 14)
6. final dismissal of appeal. (Para 15)

ORDER :

1. An intra-court appeal has been preferred as against the order dated 06- 06-2025 passed in WP.No.18359 of 2025 on the file of this Court.

2. Medical aspirants had filed five writ petitions in W.P.Nos.18359, 19359, 19337, 19369 & 19004 of 2025 for a common relief. The common ground urged in the writ petitions is that there was a power outage during NEET (UG) 2025 examination in the following centres, viz. (1) PM Shri Kendriya Vidyalaya CRPF, Avadi, (ii) Government Girls Higher Secondary School, Ponniamman Koil Stree, Kundrathur, (iii) Padma Seshadri Bala Bhavan Senior Secondary School, K.K.Nagar, (iv) PM Shri Kendriya Vidyalaya, Minambakkam. The appellants/writ petitioners filed WP.No.18359 of 2025 seeking a direction to the National Test Agency (NTA), third respondent, to consider their representation and conduct re- examination for them and for the similarly affected candidates as well.

3. The Writ Court vide common order dated 06.06.2025 dismissed all the five writ petitions, aggrieved by which, the petitioners in W.P.No.18359 of 2025 have preferred the present appeal.

4. The learned counsel appearing for the appellants would submit that the grievance of the appellants was not merely the occurrence of power outage, but, a complete breakdown of exam conditions from 3.00 p.m. to 4.15 p.m. including lack of lighting due to power failure caused due to heavy rainfall and darkened skies and gross inequality in exam conditions compared to other exam centres. The report of the NTA is not fair, complete and conclusive, despite material and factual inaccuracies, incomplete findings and lack of contemporaneous objective evidence, particularly, CCTV footage, which was neither disclosed to the appellants nor examined by the Court, since the objections of the appellants to the speaking order have been filed at the time of hearing writ petitions. Further, the learned counsel would submit that in spite of the power outage, the examination centre did not provide any compensatory time and have not arranged for any power backup. Hence, it is just and necessary to conduct re-examination for the appellants and prayed to allow the writ appeal.

5. Per contra, the learned Additional Solicitor General appearing for the first respondent and third respondent/NTA would submit that though there was a brief power outage there was no impact upon the performance of the candidates as the exam was conducted during the daytime. The candidates were not moved from their assigned seats and the disruption was minor and the same is seen from the screenshots of the CCTV footage, which is placed before this Court pertains to the multiple rooms including the room, where the appellants were seated and the images clearly shows that the examination rooms had large windows with glass panes that allowed ample ambient daylight to enter. Even during the short period between power outage and generator restoration, the rooms remained sufficiently illuminated due to natural light and the candidates continued writing without interruption and thus, the lighting conditions remained conducive to the fair conduct of the examination. It is his further submission that out of thirteen appellants one of the appellants had attempted to attend 179 questions out of 180 questions. Similarly, five appellants have attempted to attend more than 140 questions out of 180 questions. Hence, he prayed to dismiss the writ appeal.

6. We have considered the submissions made on either side and perused the records.

7. This Court vide order dated 10.06.2025 directed the third respondent/NTA to produc

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