Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(Del) 5118

IN THE HIGH COURT OF DELHI AT NEW DELHI
Jasmeet Singh, J
Shlok Bhardwaj – Appellant
Versus
Union of India – Respondent
W.P.(C) 981/2026

Advocates:
For the Appellants/Petitioners:Shlok Bhardwaj (Petitioner-In-Person)
For the Respondents: Ms. Avshreya Pratap Singh Rudy, Mr. Ankit Khatri, Ms. Usha Jamnal, Ms. Nyasa Sharma (for UOI); Mr. Sanjay Khanna, Ms. Pragya Bhushan, Ms. Vilakshana Dayma, Ms. Anshu Kumari (for NTA)

Failure of biometric verification during an examination creates continuous apprehension that materially impairs a candidate's performance, requiring restoration of the candidate to the position they would have occupied under fair conditions.

Headnote:(A) Constitution of India - Article 226 - Code of Civil Procedure, 1908 - Section 151 - Examination process - Biometric verification - Challenge to denial of fair opportunity - Petitioner’s daughter could not complete Aadhaar verification before examination, causing stress; subsequent verification at 10:34 AM during exam caused further disturbance - Grievance Redressal Committee found no procedural irregularity based on CCTV footage - Writ petition filed for permission to reappear in JEE Engineering Entrance Exam Session-I. (Paras 1-4)

(B) Examination fairness - A candidate must be comfortable both in mind and environment; technical issues like failed biometric verification causing fear of disqualification can materially impair performance - Performance under stress cannot be equated with normal conditions - Mere fact of attempting questions does not prove no prejudice - Fairness requires not only physical access but also mental equilibrium free from procedural uncertainties. (Paras 10-13)

(C) Distinction - Judgment in National Testing Agency v. Satya Nishth (LPA 490/2025) - Distinguished: in that case candidate sought grace marks after exam concluded, while here re-examination is still possible as session continues - Division Bench’s observation about re-examination not being available in that case not applicable. (Paras 14-15)

Facts of the case:
The petitioner’s daughter, while appearing for JEE Engineering Entrance Examination, could not complete Aadhaar verification at the examination centre despite reporting on time. Her Aadhaar remained blocked for a considerable period, causing mental stress. Verification was completed only midway through the examination. The Grievance Redressal Committee, after reviewing CCTV footage, found no procedural irregularity or repeated disturbance. The petitioner seeks permission for his daughter to reappear in the examination, as Session-I continues till 28.01.2026.

Findings of Court:
The Court held that the petitioner’s daughter suffered prejudice due to continuous apprehension from failed biometric verification. The Grievance Committee’s approach based on technical points was not the correct way to assess difficulties faced by candidates. The Court distinguished the Division Bench judgment in Satya Nishth, noting that here an opportunity to reappear still exists as the examination session continues.

Issues: Whether failure of biometric verification before and during the examination caused prejudice to the candidate, and whether she should be permitted to reappear in the ongoing examination session.

Ratio Decidendi: The fairness of an examination process requires not only physical access but also ensuring that candidates are not subjected to avoidable procedural uncertainties undermining mental equilibrium. Performance under stress cannot be equated with normal conditions. When a candidate is placed in a situation of continuous apprehension from technical failures, it inevitably affects performance, and the mere fact of continuing to attempt questions does not prove absence of prejudice.

Result: The petitioner’s daughter is permitted to participate in the examination to be held the next day (28.01.2026), with the result subject to further orders.

Table of Content
1. petitioner seeks reappearance due to biometric verification failure causing mental stress. (Para 1 , 2 , 3)
2. grievance committee found no procedural irregularity; respondent relies on satya nishth judgment. (Para 4 , 5 , 6 , 7 , 8)
3. biometric failure causes continuous apprehension and adversely affects candidate performance. (Para 9 , 10 , 11 , 12 , 13)
4. distinguished satya nishth; permitted reappearance as session continues, result subject to further orders. (Para 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27)

ORDER

% 27.01.2026

1. This is a writ petition filed under Article 226 of the Constitution of India read with Section 151 of the CPC, 1908 seeking the following relief:

“(A) Issue appropriate writ/ direction/ order to Respondents to permit candidate Shivanjali Bhardwaj (Roll no. UP090100390 and Application no. 260310097331) to REAPPEAR in JEE Engineering Entrance Exam Session-I (preferably afternoon shift) which shall continue till 28.01.2026…”

2. When the matter came up for hearing on 22.01.2026, the learned Standing Counsel for the respondent No. 1 was requested to obtain instructions from respondent No. 2 regarding the averments made in the petition.

3. The brief facts of the case are that while appearing for the JEE Engineering Entrance Examination, the petitioner’s daughter’s Aadhaar verification could not be completed at the examination centre despite her reporting on time. Owing to the failure of the verification process, her Aadhaar remained blocked for a considerable period, causing her severe mental stress and anxiety. The verification process was successfully completed only midway through the examination. It is further stated by the petitioner that several other candidates seated in the same examination room, i.e., Room B-4, faced an identical issue.

4. Mr. Khanna, learned standing counsel appearing for the respondent No. 2 has handed over a copy of the minutes of the Grievance Redressal Committee where it has been stated as under:

“Minutes of the Meeting (First Case)

A Grievance Redressal Meeting was held on 24 January 2026 at 11:00 AM at NTA office to hear the case regarding alleged disturbance during examination and biometric authentication process. The following members of the Grievance Redressal Committee and the Father of the candidate were present in the meeting:

Committee Members:

1. Prof. V.K. Jain, Former Vice Chancellor-Chairman

2. Prof. G.B Reddy, (Retired), IIT Delhi

3. Prof. H.C Gupta, Senior Advisor, NTA

Complainant/ Petitioner:

1. Sh. Shlok Bhardwaj Father of the Candidate (Petitioner)

Agencies:

1. TCS Team

2. E&Y Team

The father of the candidate submitted before the committee that:

1. The candidate reported repeated biometric authentication attempts by examination functionaries leading to disturbance during the examination, which, according to him, adversely affected the candidate's performance.

2. The candidate was disturbed multiple times during the examination for biometric verification and handprint authentication.

3. The candidate arrived at the examination centre at approximately 07:15-07:20 AM and was present at the biometric verification area. Initial biometric attempts were made but due to failure of biometric process candidates were made so many attempts for verification.

Some Video Evidences were Placed Before the Committee and the father of the Petitioner. The Committee was shown CCTV footage from multiple time stamps, beginning from the candidate's entry at the examination centre at around 07:20 AM. The footage demonstrated that:

Initial biometric verification attempts occurred before the commencement of the examination.

The candidate was seated at her desk by 08:53 AM, prior to the start of the examination.

No interruption or disturbance to the candidate was observed during the examination period until approximately 10:34 AM.

At 10:34 AM, the invigilator approached the candidate once for additional biometric authentication. The interaction lasted less than one m

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2026 Supreme(Online)(Del) 5118

IN THE HIGH COURT OF DELHI AT NEW DELHIJasmeet Singh, JShlok Bhardwaj – AppellantVersusUnion of India – RespondentW.P.(C) 981/2026

Failure of biometric verification during an examination creates continuous apprehension that materially impairs a candidate's performance, requiring restoration of the candidate to the position they would have occupied under fair conditions.

IN THE HIGH COURT OF DELHI AT NEW DELHI
Jasmeet Singh, J
Shlok Bhardwaj – Appellant
Versus
Union of India – Respondent
W.P.(C) 981/2026