Rajasthan High Court Upholds RPSC RAS 2023 Preliminary Exam Answer Key, Limits Judicial Review

Jaipur: The Rajasthan High Court has dismissed a batch of writ petitions challenging the final answer key of the Rajasthan State and Subordinate Services Combined Competitive Examination-2023 (RAS 2023) Preliminary Exam. Justice SameerJain , presiding over the case with S.B. Civil Writ Petition No. 18130/2023 ( Prema Ram Patel and Ors. vs. State of Rajasthan and Ors) as the lead matter, held that the scope of judicial review in such matters is extremely limited and courts should not interfere with expert opinions unless the answer key is "palpably and demonstrably erroneous."

The petitioners, unsuccessful candidates in the preliminary exam held on October 1, 2023, had challenged the final answer key released by the Rajasthan Public Service Commission (RPSC) on October 20, 2023. They contended that the RPSC had failed to adequately consider their objections against the model answer key, resulting in incorrect answers that led to their disqualification for the Mains examination.

Background of the Case

The RAS 2023 examination process began with an advertisement issued by the RPSC on June 28, 2023. The preliminary exam, consisting of General Knowledge and General Science papers, was conducted on October 1, 2023. A model answer key was published on the same day, and objections were invited from candidates between October 2 and October 4, 2023.

According to the court record, the RPSC received objections against 90 questions from aggrieved candidates. These objections were referred to subject matter experts, who, after assessing the objections and relying on authentic study material, submitted a report. Based on this expert report, the RPSC deleted 5 questions, changed the answers to 3 questions, and retained the original answers for the remaining 82 questions. The final answer key and the preliminary exam results, along with cut-off marks, were published on October 20, 2023. The petitioners failed to qualify based on this result.

Notably, the court observed that out of the 569 petitioners, only 93 had actually raised objections during the prescribed timeframe.

Petitioners' Contentions

Senior Counsel Mr. R. N. Mathur, along with other counsel for the petitioners, argued that the RPSC's failure to correctly examine objections was arbitrary and violated their fundamental rights. They sought the quashing of the final answer key and result, a fresh consideration of their objections, preparation of a revised answer key, and a revised result declaring eligible petitioners qualified for the Mains examination.

Relying on judgments like Kanpur University and Ors. vs. Samir Gupta and Ors. , they argued that judicial review is permissible when an answer key is palpably and demonstrably erroneous, evident even to a prudent man's ordinary understanding. They stressed the need for transparency and fairness in public employment exams and presented arguments based on authentic textbooks to prove the incorrectness of certain answers.

RPSC's Defence

Mr. Yuvraj Samant , learned counsel for the RPSC, strongly opposed the petitions, emphasizing the limited scope of judicial review in administrative matters. He argued that courts, lacking subject expertise, should only review the decision-making process , not the correctness of the decision itself. He submitted that the RPSC had followed the due process by inviting objections, referring them to experts, and finalizing the answer key based on the expert reports. Mr. Samant cited several Supreme Court judgments, including Ran Vijay Singh and Ors. vs. State of U.P. and Ors. and Vikesh Kumar Gupta and Ors. vs. State of Rajasthan and Ors. , to support the argument that courts should defer to expert opinions and should not re-evaluate answer sheets themselves.

Court's Analysis and Decision

Justice Jain meticulously examined the established legal principles regarding judicial review of answer keys in public examinations, drawing heavily from Supreme Court precedents. The court reiterated that academic matters are best left to experts, and courts should be extremely reluctant to substitute their own views.

The judgment highlighted that interference by courts under Article 226 is permissible only in "rare or exceptional cases" where the disputed answer key is "palpably and demonstrably erroneous." Critically, the court explained that "palpably and demonstrably erroneous" means an error that is self-evident and discernible by a mere glimpse, not one that requires an inferential process of reasoning, rationalization, or deep academic research. If two equally valid interpretations are possible, the answer is not demonstrably erroneous.

Applying this standard, the court examined several disputed questions and concluded that discerning the alleged errors would require delving into complex academic analysis and comparative study, which is beyond the scope of judicial review under Article 226. The court found no error "apparent on the face of the record" in the final answer key that would compel interference.

The judgment acknowledged that the RPSC had followed the prescribed procedure by inviting objections and consulting experts, leading to the deletion of 5 questions and changes in 3 answers. This demonstrated that the process for addressing objections was followed.

Citing Ran Vijay Singh , the court reiterated the principle that the correctness of key answers should be presumed, and in case of doubt, the benefit should go to the examination authority, not the candidate. The court stressed the need to avoid unending litigation over public employment selections, which affects the careers of many candidates.

Consequently, the Rajasthan High Court found no grounds to interfere with the final answer key or the results declared by the RPSC.

"As long as all the candidates who sat in the examination, are treated equally viz-a-viz the system of evaluation in place, sans discrimination, then no grievance qua the impugned examination subsists," the court observed.

Concluding that the petitioners failed to demonstrate that the final answer key was palpably and demonstrably erroneous, the court dismissed the batch of writ petitions.