Bombay High Court Dismisses IIT Aspirant's Plea for Corrected JEE Mains Scorecard Due to Disputed Facts and Failed QR Verification. Upholding NTA's Stand, Court Holds That Writ Court Cannot Enter Dense Factual Disputes and Presumes Validity of Official Records Under Section 114 of Indian Evidence Act, 1872.

High Court: Bombay High Court Bench: BOMBAY
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Case Note & Summary

The petitioner, an IIT aspirant, appeared for two writ petitions arising from his participation in the JEE (Mains) 2025 examination conducted by the National Testing Agency (NTA). In WP No. 3649 of 2025, he sought a direction to NTA to issue a corrected scorecard showing a percentile of 99.5193354 instead of the displayed 83.3493354, claiming that his originally downloaded scorecard on 11.02.2025 briefly reflected the higher percentile before changing. He also sought an update of his rank. In WP No. 5574 of 2025, filed after appearing for the second session, he additionally sought deletion of the 'UFM' (unfair means) remark and the debarment for 2025-26 and 2026-27, along with permission to register for JEE (Advanced) 2025. The petitioner alleged that he had 54 correct answers, 9 wrong, and 12 unattempted, thus securing 207 out of 300 marks, which should have yielded the higher percentile. The NTA opposed the petitions, contending that the scorecard with 99.5193354 was fabricated and not downloaded from its website; the document conspicuously bore a 'Sample Result' watermark, and no such practice existed. The NTA produced a question-wise chart showing discrepancies between the petitioner's claimed answers and the official answer key. It invoked clause 5.5.1(h)&(r) of the JEE (Mains) 2025 Information Bulletin and the Public Examination (Prevention of Unfair Means) Act, 2024. Respondent IIT Kanpur, organizing JEE Advanced, argued that even if the petitioner had sufficient marks, the UFM status disqualified him under the applicable rules. The court, after considering rival submissions, declined to interfere. It noted that the scorecard relied on by the petitioner had suspicious time stamps and failed to pass a QR code verification test conducted by the court itself; scanning the QR code revealed a percentile of only 83.3493354, not 99.5193354. The court held that the dispute raised involved dense factual questions which a writ court cannot adjudicate, and assessing individual marks is best left to experts. It placed reliance on the Delhi High Court's decisions in Vibhuti Negi v. National Testing Agency and Selishia Mohandas v. Union of India, the latter citing the presumption of regularity under Section 114 of the Indian Evidence Act, 1872. Consequently, the court refused to issue any mandamus for correction of the scorecard or permission to appear for JEE Advanced. However, noting the petitioner's young age and educational stakes, the court granted liberty to adopt appropriate proceedings or file a representation to challenge the debarment, with all contentions on merits kept open. Both writ petitions were disposed of with no order as to costs.

Headnote

A) Education Law - Examination Results - Disputed Facts - Constitution of India, Article 226 - Petitioner claimed discrepancy in scorecard and sought correction - Court found that the scorecard relied on had "Sample Result" endorsement and failed QR code verification - Held that writ court should not enter dense factual thicket of disputed questions, no interference warranted (Paras 10-12).

B) Education Law - Examination Results - QR Code Verification - Not mentioned - Court verified QR code on petitioner's scorecard pdf and found it showed his percentile as 83.34 instead of 99.51 as claimed - Held that QR code verifiable scorecard establishes official record and puts to rest the dispute (Para 11).

C) Evidence - Presumption of Regularity - Indian Evidence Act, 1872, Section 114 - Court referred to precedent Selishia Mohandas v. Union of India which relied on Section 114 to presume correctness of NTA records - Held that similar presumption applies here (Para 13).

D) Education Law - Debarment for Unfair Means - JEE (Mains) 2025 Information Bulletin, Clause 5.5.1(h)&(r) - Petitioner debarred for 2025-26 and 2026-27 with UFM endorsement - Court granted liberty to challenge debarment or seek reconsideration, with contentions kept open (Paras 14-15).

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Issue of Consideration

Whether the petitioner is entitled to direction for corrected scorecard and permission to appear for JEE Advanced; whether the debarment is justified.

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Final Decision

The Court declined to interfere in writ jurisdiction, finding the scorecard relied upon by petitioner was suspicious, failed QR verification, and involved disputed facts. It granted liberty to the petitioner to challenge the debarment by appropriate proceedings or representation. Both writ petitions disposed of with no costs.

Law Points

  • Legal points not extracted
  • Writ court should not enter into dense factual thicket
  • QR code verification serves to confirm authenticity
  • Presumption under Section 114 of Indian Evidence Act
  • 1872 in favour of official records
  • Disputed questions of fact are not amenable to writ jurisdiction
  • Courts should not interfere in assessment of marks by expert bodies
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Case Details

2025 LawText (BOM) (05) 54

Writ Petition No. 3649 of 2025 and Writ Petition No. 5574 of 2025

2025-05-02

A.S. Chandurkar, M.M. Sathaye

Citation not available

Mr. Ranjit Bhosle with Dr. Prashant Mali and Ms. Smita Gaidhani for Petitioner; Ms. Gargi Warunjikar for Respondent No.1/UOI in WP/3649/2025; Mr. Neel Helekar with Ms. Gargi Warunjikar for Respondent No.1/UOI in WP/5574/2025; Mr. Rui Rodrigues with Mr. Jainendra Sheth for Respondent No.2; Mr. Arsh Misra for Respondent No.3 in WP/5574/2025

Shantanu Bhopale

1. The Union of India through the Department of Higher Education, 2. The Director General, National Testing Agency, New Delhi, 3. The Organizing Chairperson JEE (Advanced) 2025, IIT, Kanpur

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Nature of Litigation

The petitioner, an IIT aspirant, filed writ petitions seeking correction of his JEE Mains scorecard and permission to appear for JEE Advanced after the NTA endorsed his result as 'UFM' and debarred him.

Remedy Sought

Petitioner sought: (i) corrected scorecard showing 99.5193354 percentile; (ii) deletion of UFM remark and debarment; (iii) independent evaluation of answer-sheet; (iv) declaration of eligibility and permission to fill JEE Advanced application.

Filing Reason

Petitioner claimed that upon downloading scorecard on 11.02.2025, his percentile initially showed 99.5193354 but later changed to 83.3493354, and that his correct marks were 207 out of 300.

Previous Decisions

Previous decisions not referenced

Issues

Whether the petitioner's scorecard as claimed reflects his true performance or is fabricated. Whether the writ court can interfere in disputed factual questions surrounding examination results. Whether the petitioner is entitled to mandamus for correction and permission to appear for JEE Advanced.

Submissions/Arguments

Petitioner: Claimed discrepancy in scorecard; argued that document properties show it was not tampered; sought relief based on his claimed correct answers. Respondent NTA: Contended that the scorecard with 99.5193354 is forged and not from NTA website; produced answer key and question-wise chart showing mismatch; stated there is no practice of issuing 'Sample Result'; invoked unfair means rules. Respondent IIT Kanpur (JEE Advanced): Pointed that even if marks were sufficient, the petitioner's UFM status disqualifies him as per eligibility rules.

Ratio Decidendi

The ratio decidendi of the judgment is that a writ court should not entertain petitions involving disputed questions of fact related to examination results, and should instead rely on available technology like QR code verification to ascertain the authenticity of scorecards; further, a presumption under Section 114 of Indian Evidence Act, 1872 operates in favor of official records maintained by examination bodies like NTA. Also, the court held that the assessment of individual marks is the domain of experts and should not be interfered with in writ jurisdiction.

Judgment Excerpts

...within realm of disputed questions of fact, it is not possible for us to adjudicate in the writ jurisdiction. the score-card-pdf relied upon by the Petitioner has failed the QR-code-validity test. Writ Court should not enter into the exercise of assessing individual marks given to questions or compare it with model answer papers etc. and it is best left to the experts. High Court of Delhi has in similar situation declined to enter into ‘dense factual thicket’ there is no question of issuing any direction or writ of mandamus to Respondent No.2 for correction of Petitioner’s score-card or marks therein or to permit the Petitioner to appear for JEE (Advanced).

Procedural History

The petitioner filed WP/3649/2025 after scorecard discrepancy on 11.02.2025; during pendency, he appeared for 2nd session of JEE Mains on 03.04.2025; thereafter he filed WP/5574/2025 impleading IIT Kanpur and challenging debarment. The matter was heard and disposed of.

Acts & Sections

  • Indian Evidence Act, 1872: Section 114
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