Supreme Court Allows Admission for One Student in Medical College Admission Dispute. Key answers were found incorrect, leading to one student's entitlement to admission based on proper interpretation of examination questions.

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Case Note & Summary

The dispute arose from the admission process for M.B.B.S. courses in Uttar Pradesh, where candidates challenged the validity of answers provided in a Multiple Choice Objective Type Test. The appellants, who were candidates, contended that the key answers supplied by the paper-setter for certain questions were incorrect according to recognized textbooks. They sought an addition of marks based on their answers, which they argued were correct. The University rejected their claims, leading to appeals in the Supreme Court after the High Court dismissed their writ petitions. The court analyzed the validity of the key answers and the students' responses, determining that if the key answer was demonstrably wrong, penalizing students for not conforming to it would be unjust. For one question, both the key answer and the students' answers were deemed incorrect, while for another question, the court found that the absence of a specified range in the question made the students' answer correct. Consequently, the court allowed one student's appeal for admission while dismissing the others, emphasizing the importance of fairness in examination standards.

Headnote

A) Education Law - Admission Criteria - Validity of Key Answers - Constitution of India, 1950, Articles 226 & 136 - The court held that if the key answer provided by the paper-setter is demonstrably wrong, it would be unfair to penalize students for not conforming to it. In this case, both the key answer and the students' answers were found incorrect for one question, while for another question, the student was entitled to admission based on the correct interpretation of the question. Held that only one student was entitled to admission (Paras 988-991).

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Issue of Consideration

Whether the key answers provided for the entrance examination were correct and if the students were entitled to admission based on their answers.

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Final Decision

The court allowed the appeal of Kumari Sunita Khare for admission to the M.B.B.S. course, while dismissing the other appeals without costs.

Law Points

  • Admission criteria
  • Multiple Choice Objective Type Test
  • Key answer validity
  • Fairness in examination
  • Educational standards
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Case Details

1983 LawText (SC) (12) 12

Civil Appeal Nos. 4116 to 4119 of 1983

1983-12-06

Tulzapurkar, V.D., Mukharji, Sabyasachi

1984 AIR 1402, 1984 SCR (1) 983, 1984 SCC (2) 319, 1983 SCALE (2) 912

R.K. Garg, A.K. Gupta, Shobha Dikshit

Abhijit Sen & Ors.

State of U.P. & Ors.

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Nature of Litigation

Writ petitions challenging the admission process based on examination answers.

Remedy Sought

Candidates sought admission to M.B.B.S. courses based on their answers.

Filing Reason

Dispute over the correctness of key answers in the entrance examination.

Previous Decisions

High Court dismissed the writ petitions challenging the University’s decision.

Issues

Validity of key answers in entrance examination Entitlement to admission based on examination performance

Submissions/Arguments

Appellants argued that the key answers were incorrect and their answers were correct according to textbooks. Respondents contended that the court's determination of correct answers was crucial for granting marks.

Ratio Decidendi

The court established that if the key answer is demonstrably wrong, it is unfair to penalize students for not conforming to it, emphasizing the need for fairness in examination standards.

Judgment Excerpts

If the ‘key-answer’ is shown to be demonstrably wrong, it would be unfair to penalise the student for not giving an answer which accords with the key-answer. In the absence of any reference to the range, Alternative No. 4 would be the correct answer.

Procedural History

The appeals arose from the dismissal of writ petitions by the High Court of Judicature at Allahabad on 24th February 1983, challenging the University’s admission decisions.

Acts & Sections

  • Constitution of India: Articles 226, 136
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