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Supreme Court Restores UPSSSC Answer Key Upholds in Exam Disputes
The has delivered a significant ruling reaffirming the in challenges to answer keys of public examinations. Setting aside a order of the , a bench comprising Justice Manoj Misra and Justice Vijay Bishnoi restored the answer key published by the for a recruitment exam, holding that courts must not interfere unless a mistake is so glaring that no is required.
The One-Mark Controversy
The dispute arose from a general knowledge question in the written examination for 3,133 Village Development Officer posts. Candidates were asked to identify the incorrectly matched pair from four options:
- Baburnama–Babur
- Shahjahannama–Mohammad Tahir
- Humayunnama–Humayun
- Tuzuk-e-Jahangiri–Jahangir
The Commission treated option B (“Shahjahannama–Mohammad Tahir”) as the correct answer, pairing each book with the person it is about . However, candidate Ashok Yadav selected option C (“Humayunnama–Humayun”), arguing that since Humayunnama was authored by Gulbadan Begum and not Humayun, this was the only incorrect pair if matched by authorship. He petitioned the High Court for one additional mark.
High Court’s Intervention
A Single Judge dismissed the on grounds of , citing the Supreme Court’s decision in . An was also dismissed. However, a was later allowed by the , which relied on an expert report dated . That report noted that if the pairing logic were based on authorship, option C would be correct, but if based on subject (whom the book is about), option B would be correct. The High Court directed the Commission to award one mark to the candidate and make recommendations accordingly.
Arguments Before the Supreme Court
Appellant (UPSSSC): Senior Counsel argued that the question did not specify authorship as the basis for pairing. Therefore, a —matching the book to its subject—led to option B as the only correct answer. He emphasised that the expert report was equivocal and did not declare option B incorrect. He further submitted that courts must respect the Commission’s expertise and that the was filed belatedly.
Respondent (Ashok Yadav & Intervenors): Senior Counsel contended that the question fell under the General Knowledge section, where knowledge of authorship is standard. Since three options matched authors and only option C did not, the Commission’s choice was . Alternatively, he argued that if both authorship and subject pairing were possible, both options B and C should be treated as correct, and the High Court’s order awarding a mark was therefore justified. Reliance was placed on to argue that courts can intervene when academic bodies act arbitrarily.
The Court’s Analysis
The Supreme Court began by reiterating the principles laid down in and . Key among them:
- Courts must of the answer key.
- Interference is warranted only if the mistake is so glaring that no inferential process is needed to detect it.
- In case of doubt, the benefit must go to the examining body, not the candidate.
Applying these principles, the Court observed that the question was silent on the pairing parameter. The Commission’s choice of subject-wise pairing was neither nor irrational. The expert report did not state that option B was wrong—it merely pointed out two possible interpretations. The candidate’s assumption that authorship was the basis was an for which the Commission could not be blamed.
“Misreading a question, or reading something into a question, often results in a wrong answer… The Court must only consider whether the question or answer as it stands is correct or not and not what it ought to have been.”
The Court further held that the High Court had overstepped its jurisdiction, especially while exercising review powers. Since neither the question nor the answer suffered from a , there was no occasion for judicial interference.
Key Observations
The judgment contains several crucial observations on the limits of judicial review in examination matters:
“If a statute, Rule or Regulation governing an examination does not permit … the court may permit only if it is demonstrated very clearly, without any ‘ or by a process of rationalization’ and only in rare or exceptional cases that a has been committed.”
“In the event of a doubt, the rather than to the candidate.”
“The overall and larger impact of all this is that suffers… This unsatisfactory situation does not work to anybody's advantage.”
Final Decision and Implications
The Supreme Court allowed the appeal, set aside the High Court’s review order, and dismissed the filed by Ashok Yadav. The Commission’s answer key stands restored. All pending applications were disposed of.
This ruling reinforces the message that courts should refrain from second-guessing examining bodies in academic and recruitment matters unless there is a clear, demonstrable error. It serves as a caution to candidates and lower courts against protracted litigation over answer keys, which can delay results and harm . The decision also underscores the importance of respecting the internal checks and balances of examination authorities.
