Supreme Court Upholds UPSSSC Answer Key, Bars Interference Unless Error Is Glaring

In a significant ruling that reinforces the boundaries of judicial oversight in examination disputes, the Supreme Court has set aside an Allahabad High Court order that directed the Uttar Pradesh Subordinate Service Selection Commission (UPSSSC) to award an additional mark to a candidate in the Village Development Officer recruitment examination. A bench comprising Justice Manoj Misra and Justice Vijay Bishnoi held that courts must presume the correctness of answer keys and interfere only when the error is so glaring and apparent that it requires no inferential reasoning.

A Disputed History Question

The case originated from the 2016 recruitment process for 3,133 Village Development Officer posts. The written examination held on June 5, 2016, included Question No. 68, which asked candidates to identify the incorrectly matched pair among four historical chronicles and their associated names. The options were:

(A) Baburnama – Babur
(B) Shahjahannama – Mohd. Taahir
(C) Humayunnama – Humayun
(D) Tuzuk-e-Jahangiri – Jahangir

The Commission's answer key treated Option 'B' as the correct answer—the incorrect pair—since the Shahjahannama describes Shahjahan's reign, not that of Mohd. Taahir. However, the respondent, Ashok Yadav, had marked Option 'C' as incorrect, arguing that Humayunnama was authored by Gulbadan Begum, not Humayun.

The Expert Report That Divided Opinions

Yadav's writ petition was initially dismissed by a single judge on grounds of laches, and an intra-court appeal was also rejected. However, in a subsequent review petition, the Division Bench relied on an expert report dated August 10, 2020, which had not been placed before the earlier courts. The report, authored by Dr. Alok Kumar of DSMNR University Lucknow and Prof. S. Victor Babu of B. B. Ambedkar University Lucknow, stated:

"If we go by the logic of Book and Author pair, the correct answer to the above question is C. ... However, if we go by the logic of Book and its description about Whom, the correct answer to the above question is B."

Based on this, the High Court directed the Commission to award one mark to the candidate, prepare a fresh recommendation, and ordered the State Government to issue an appointment. The Commission appealed to the Supreme Court.

Courts Must Exercise Restraint

The Supreme Court framed the issue as "whether the High Court was justified in interfering with Commission's decision to pick Option 'B' as the only correct answer." The Court reiterated the principles laid down in Ran Vijay Singh v. State of U.P. and U.P. Public Service Commission v. Rahul Singh , which emphasize that courts should presume the correctness of key answers and that "the onus is on the candidate to not only demonstrate that the key answer is incorrect but also that it is a glaring mistake which is totally apparent and no inferential process or reasoning is required to show that the key answer is wrong."

The bench observed that the question did not specify any parameter for pairing the books. In the absence of such a parameter, a "commonsense approach" of matching each book with its subject—the approach adopted by the Commission—could not be considered arbitrary or irrational. The Court noted that the expert report itself was "equivocal" and did not declare Option 'B' to be incorrect. It merely presented two possible interpretations depending on the reader's perception.

No Glaring Error Found

Applying the strict test for judicial review , the Supreme Court found that neither the question nor the Commission's chosen answer suffered from any glaring error . The Court held that the candidate had "applied inferential logic to read into the question 'authorship of the book' as the guiding principle" when no such principle was discernible from a plain reading . "Thus, the writ petitioner committed an assumptive mistake which cannot be attributed to the question or the examining body," the bench stated.

The Court also rejected the argument that the question's placement in the General Knowledge section mandated authorship as the basis for pairing. "A question is to be understood as it stands and not what it ought to have been," the judgment noted.

What This Means for Future Challenges

Concluding that the High Court had "clearly overstepped its jurisdiction" in interfering with the answer key, particularly in its review jurisdiction, the Supreme Court allowed the appeal, set aside the impugned order, and dismissed the respondent's writ petition.

The ruling reinforces the message that constitutional courts must exercise "great restraint" in examination matters and that sympathy for an individual candidate cannot derail the entire selection process. As the Court observed in Ran Vijay Singh , "the entire examination process does not deserve to be derailed only because some candidates are disappointed or dissatisfied or perceive some injustice having been caused to them by an erroneous question or an erroneous answer." This judgment serves as a clear reminder that the benefit of any doubt must go to the examining authority, not the candidate, and that only patent, non-inferential errors can justify judicial intervention.