Case Note & Summary
The petitioner, Atul Baban Rupnavar, filed a writ petition under Article 226 of the Constitution of India challenging an order of the Maharashtra Administrative Tribunal dated 6 February 2023 (though the judgment text indicates the order was passed in 2024, as the OA was filed in 2024) dismissing his Original Application No.143 of 2024. The petitioner had applied for the post of Junior Engineer (Group 'B') advertised by the Public Works Regional Department, with the examination conducted by Tata Consultancy Services (TCS). The petitioner appeared for the exam and on 4 January 2024 reviewed his response sheet, finding ambiguity in Question ID No.630680511689, which asked for the antonym of 'Alleviate' with options: 1. Heighten, 2. Relieve, 3. Amend, 4. Enhance. The petitioner selected Option 4 (Enhance) as correct, but the respondents' answer key marked Option 1 (Heighten) as correct. On 10 February 2024, the additional list of candidates was published, and the petitioner was placed at Serial No.8 with 163.01774 marks, while the cut-off for Open Category was higher. The petitioner approached the Tribunal, which dismissed his application. In the High Court, the petitioner argued that both 'Heighten' and 'Enhance' could be antonyms of 'Alleviate', and that the question was ambiguous. The respondents, represented by the State and TCS, contended that the answer key was prepared by experts and that 'Heighten' is the precise antonym. The court examined dictionary meanings: 'Alleviate' means to reduce or make less severe; 'Heighten' means to increase or make higher; 'Relieve' is a synonym; 'Amend' means to improve; 'Enhance' means to increase in value or quality. The court held that 'Heighten' is the direct antonym as it denotes an increase in intensity, while 'Enhance' implies improvement rather than mere increase. The court found no ambiguity and held that the scope of judicial review in academic matters is limited; the court cannot substitute its opinion for that of experts unless the key is patently erroneous or arbitrary. Since the key was not arbitrary, the petition was dismissed. The court also noted that the Tribunal's order was correct and required no interference.
Headnote
A) Service Law - Recruitment Examination - Answer Key Challenge - Judicial Review - The petitioner challenged the answer key for an antonym question in the Junior Engineer (Group 'B') examination conducted by Tata Consultancy Services for the Public Works Department. The court held that the scope of judicial review in academic matters is limited and that the court should not substitute its own opinion for that of experts unless the key is patently erroneous or arbitrary. (Paras 2-6) B) Interpretation of Words - Antonym - 'Alleviate' - The court examined the dictionary meanings of 'Alleviate', 'Heighten', 'Relieve', 'Amend', and 'Enhance' and concluded that 'Heighten' is the correct antonym as it means to increase or make higher, while 'Alleviate' means to reduce or make less severe. The court found no ambiguity in the question. (Paras 4-5) C) Constitutional Law - Article 226 - Writ Jurisdiction - Interference in Answer Key - The court reiterated that under Article 226 of the Constitution of India, the High Court can interfere only if the answer key is demonstrably wrong or arbitrary. Since the key was based on expert opinion and was not patently erroneous, the petition was dismissed. (Para 6)
Issue of Consideration
Whether the answer key for Question ID No.630680511689 in the Junior Engineer examination is erroneous and whether the court should interfere with the key prepared by the expert body.
Final Decision
The writ petition is dismissed. The order of the Maharashtra Administrative Tribunal is upheld. No order as to costs.
Law Points
- Judicial review of answer keys
- scope of interference in academic matters
- antonym interpretation
- deference to expert bodies
