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2026 Supreme(Ori) 750
ORISSA HIGH COURT : CUTTACK
ANANDA CHANDRA BEHERA, J.
Miss. Preeti Snigdha Priyadarsini Meher (Minor) - Petitioner
Versus
Central Board of Secondary Education, New Delhi – Respondent
WP(C) No.37316 of 2025
Decided On : 20-03-2026
For the Petitioner:Mr. Kunal Kumar Swain, Advocate
For the Respondent: Mr. T. Pattanayak, Adv.
A student's exam result cannot be canceled without direct evidence of malpractice; decisions based on assumptions violate the right to equality under Article 14.
Headnote:(A) Constitution of India, 1950 - Articles 226 and 227 - Examination malpractice and result cancellation - Petition for quashing order canceling petitioner's exam results alleging unfair means; court found no direct evidence or official report of malpractice from invigilators or authorities, resulting in discrimination and violation of equality rights under Article 14. (Paras 6, 8, 10)
(B) Legal principles on examination conduct - Authorities must base decisions on concrete evidence, not presumptions or conjectures about similarity of answers; previous cases support the necessity for valid proof of malpractice. (Paras 8, 9)
Facts of the case:
The petitioner, a Class-XII student, had her exam results canceled on grounds of alleged malpractice, specifically similar answers in two subjects, despite no official complaints or evidence of wrongdoing.
Findings of Court:
The court ruled that the cancellation of the petitioner's result was not sustainable due to lack of direct evidence, thus quashing the impugned order from the CBSE.
Issues: Whether the cancellation of the petitioner's exam result for alleged malpractice was legally justified.
Ratio Decidendi: The court emphasized that decisions on exam results should be supported by direct evidence of malpractice, rejecting conclusions based on assumptions.
Result: The cancellation of the petitioner's exam result is quashed, directing the publication of her results.
| Table of Content |
|---|
| 1. petitioner's request to quash examination result. (Para 1 , 2) |
| 2. allegations of discrimination and malpractices. (Para 3 , 4) |
| 3. summary of arguments heard by the court. (Para 5) |
| 4. legal sustainability of cancellation of result. (Para 6 , 7 , 8) |
| 5. cancellation based on presumption lacking evidence. (Para 9) |
| 6. writ petition allowed in part. (Para 10) |
| 7. directions for publication of results. (Para 11 , 12) |
JUDGMENT :
ANANDA CHANDRA BEHERA, J.
1. This writ petition under Articles 226 and 227 of the Constitution of India, 1950 has been filed by the petitioner praying for quashing the impugned Order dated 26.05.2025 (Annexure-2 series) issued by the Central Board of Secondary Education, Regional Office, Bhubaneswar and for issuance of necessary directions to the Opp. Parties to publish the result of the petitioner, in respect of her Senior School Certificate Examination, 2025 (Class-XII) within a stipulated time and to pass such other order/orders or direction/directions as the Courts deems fit and proper in order to give complete relief to the petitioner.
2. The case of the petitioner is that, she (petitioner) was a regular student of Class-XII of Zenith Lions Gurukul, Padampur in the District of Bargarh. He (petitioner) appeared her Senior School Certificate Examination, 2025 (Class-XII) under the Central Board of Secondary Education in Padampur Public School in the District of Bargarh as a regular student on the basis of the admit card vide Annexure-1 issued to her by the CBSE (Opp. Party No.1). Though, in the said examination, she (petitioner) had done extremely well, but her result in the website was published on dated 13.05.2025 reflecting as R.L. (Result Later) and no marks were awarded to her in any paper. Subsequent thereto, the Regional Director, Central Board of Secondary Education, Regional Office, Bhubaneswar issued official order dated 26.05.2025 in respect of various examinations centres, in which the petitioner result was shown as UFM (Unfair Means) as in respect of two papers i.e. English (Subject Code:301) and Chemistry (Sbuject Code:043), she found to have adopted unfair means assigning the reasons in the said order that, same wrong answer of question No.2 in set 2 in several adjacent students and found the same pattern, structure, vocabulary and content at question Nos.9 to 13 .
3. To which, the petitioner challenged by filing this Writ Petition praying for quashing the Annexure-2 series and to publish her result taking various grounds.
4. As per the writ petition of the petitioner, though, the result of almost all candidates of the same centre has been published, except few like the petitioner and the result of the petitioner has been cancelled by the Opp. Parties clandestinely taking a discriminating attitude towards her (petitioner), for which, the above order dated 26.05.2025 (Annexure-2 series), i.e. the cancellation of the entire result of the petitioner alleging malpractice in two subjects i.e. Chemistry and English Core on the ground of giving similar answers in most of the questions along with MCQs with adjacent students of that centre cannot be sustainable under law.
5. I have already heard from the learned counsel for the petitioner and learned counsel Mr. T. Pattanayak for the Opp. Parties.
6. As per the rival submissions of the learned counsels of both the sides on the basis of the writ petition, the crux of this writ petition is that,
“whether the impugned order dated 26.05.2025 Annexure-2 series issued by the C.B.S.E., Regional Office, Bhubaneswar (Opp. Party No.2) regarding the cancellation of the result of Senior School Certificate Examination, 2025 (Class-XII) of the petitioner alleging her indulgence in adopting unfair means during examination in two subjects i.e. Chemistry & English giving similar answers in some questions thereof with other students in the same centre is sustainable under law?”
7. It is the undisputed case of the parties that,
“neither the centre, in which the petitio
