Madras High Court Dismisses Petition Challenging SI Recruitment Exam Pattern — No Deviation from Syllabus Found. Tamil Language Questions Were Part of Part-I Eligibility Test, Not Part-II Main Written Examination; No Right to Specific Exam Pattern.

High Court: Madras High Court
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Case Note & Summary

The writ petition was filed by two candidates, B.Gurusamy and S.Anandaraja, challenging the notification dated 04.04.2025 issued by the Tamil Nadu Uniformed Services Recruitment Board for direct recruitment to the post of Sub Inspector of Police, and the subsequent provisional selection list. The petitioners alleged that the Board deviated from the prescribed syllabus by omitting Tamil language questions in Part II Main Written Examination (Part B - Psychology Test and Communication Skills) held on 21.12.2025. They sought quashing of the notification and selection list, and a direction to conduct a fresh examination or re-evaluate in accordance with the official syllabus. The Court examined the notification which prescribed a two-part examination: Part I - Tamil Eligibility Test (100 questions, 100 marks, minimum 40 marks to qualify), and Part II - Main Written Examination consisting of Part A (General Knowledge) and Part B (Psychology Test and Communication Skills) carrying a total of 70 marks, with a minimum of 25 marks to qualify. The Court noted that the syllabus for Part II Part B only mentioned 'Psychology Test and Communication Skills' and did not specify Tamil language. The Tamil language test was explicitly covered in Part I as an eligibility test. The Court held that there was no deviation from the syllabus as the Board had already tested Tamil language proficiency in Part I. The Court also observed that the petitioners participated in the examination without any protest and only challenged after the results were declared, and that candidates have no vested right to a particular examination pattern. The Court dismissed the writ petition, finding no merit in the challenge.

Headnote

A) Service Law - Recruitment Examination - Syllabus Interpretation - Deviation from Syllabus - The petitioners challenged the notification and provisional selection list for Sub Inspector of Police recruitment, alleging that the Board omitted Tamil language questions in Part II Main Written Examination contrary to the syllabus. The Court held that the syllabus for Part II Part B only included 'Psychology Test and Communication Skills' and did not specify Tamil language; the Tamil language test was Part I (Eligibility Test). Therefore, there was no deviation from the syllabus. (Paras 2-5)

B) Service Law - Recruitment Examination - No Right to Particular Exam Pattern - Participation in Selection - The petitioners participated in the examination without protest and only challenged after results were declared. The Court held that candidates have no vested right to a particular examination pattern, and the Board has the discretion to design the selection process. (Paras 6-7)

C) Service Law - Recruitment Examination - Tamil Language Testing - Part I Eligibility Test - The notification clearly provided that Part I was a Tamil Eligibility Test of 100 marks, and only those who scored minimum 40 marks would have their main written examination evaluated. The Court found that the Board had already tested Tamil language proficiency in Part I, and there was no requirement to test it again in Part II. (Paras 2-4)

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Issue of Consideration

Whether the Tamil Nadu Uniformed Services Recruitment Board deviated from the prescribed syllabus by omitting Tamil language questions in Part II Main Written Examination, and whether the petitioners have a right to challenge the examination pattern after participating in the selection process.

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Final Decision

The writ petition is dismissed. No costs. Consequently, connected miscellaneous petitions are closed.

Law Points

  • Recruitment examination pattern
  • syllabus interpretation
  • no right to particular exam pattern
  • Tamil language testing
  • eligibility test vs main examination
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Case Details

2026 LawText (MAD) (03) 236

WP(MD)No.2673 of 2026 & WMP(MD)Nos.2267, 2269, 2270, 2274 of 2026

2026-03-11

B.PUGALENDHI

2026:MHC:979

Mr.N.Marimuthu for Petitioners, Mr.Veera Kathiravan (Additional Advocate General) assisted by Mr.C.Venkatesh Kumar (Special Government Pleader) for Respondents

B.Gurusamy and S.Anandaraja

The Director General of Police / Chairman, Tamil Nadu Uniformed Services Recruitment Board, The Member Secretary, Tamil Nadu Uniformed Services Recruitment Board, The Superintendent of Police, Tirunelveli District, The Superintendent of Police, Tenkasi District

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Nature of Litigation

Writ petition under Article 226 of the Constitution of India challenging the notification and provisional selection list for recruitment of Sub Inspector of Police.

Remedy Sought

Quashing of the impugned notification and provisional selection list, and direction to conduct fresh examination or re-evaluate Part II Main Written Examination in accordance with the official syllabus.

Filing Reason

Alleged deviation from syllabus by omitting Tamil language questions in Part II Main Written Examination.

Issues

Whether the Board deviated from the prescribed syllabus by omitting Tamil language questions in Part II Main Written Examination? Whether the petitioners have a right to challenge the examination pattern after participating in the selection process?

Submissions/Arguments

Petitioners argued that the syllabus for Part II Part B included communication skills in Tamil, and the Board omitted Tamil language questions, causing prejudice. Respondents argued that Part I was the Tamil Eligibility Test, and Part II Part B only tested Psychology and Communication Skills without specifying Tamil; no deviation from syllabus.

Ratio Decidendi

The syllabus for Part II Part B of the main written examination only included 'Psychology Test and Communication Skills' and did not specify Tamil language; the Tamil language test was separately conducted as Part I (Eligibility Test). Therefore, there was no deviation from the syllabus. Candidates have no vested right to a particular examination pattern, and the Board has discretion to design the selection process.

Judgment Excerpts

As per the notification, the pattern of examination is as under: (1) Part-I – Tamil Eligibility Test consisting of 100 questions for 100 marks... (2) Part-II – consisting of main written examination of Part-A (General Knowledge) and Part-B (Psychology) carrying a total of 70 marks. The syllabus for Part-B of Part-II of the main written examination includes the testing of communication skills of the candidates in effective usage of Tamil... The Court held that there was no deviation from the syllabus as the Board had already tested Tamil language proficiency in Part I.

Procedural History

The writ petition was filed on an unspecified date, reserved on 25.02.2026, and delivered on 11.03.2026.

Acts & Sections

  • Constitution of India: Article 226
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