Case Note & Summary
The petitioner, a locomotor disabled person with 62% disability, appeared for the Combined Civil Services Examination-IV (Group-IV) conducted by the Tamil Nadu Public Service Commission on 09.06.2024, with the aid of a scribe. After completing the examination, the petitioner failed to affix his signature or thumb impression on the OMR answer sheet, as required by the Commission's instructions. The instructions, issued for candidates with benchmark disabilities, allowed a candidate unable to sign to affix left thumb impression, and if unable, right thumb impression; only candidates unable to use both hands were permitted to leave the signature/thumb impression columns blank. The petitioner claimed paralysis in his right hand but did not state that both hands were paralysed. Consequently, the TNPSC rejected the answer sheet as invalid and did not evaluate it. The petitioner filed a writ petition under Article 226 of the Constitution, seeking certiorarified mandamus to quash the declaration of results insofar as it concerned him, and to direct evaluation of his OMR sheet and his participation in further stages. He argued that a lenient approach should be taken given his disability, and that even without signature, the answer sheet could be identified through registration number comparison. The respondents contended that the instructions were mandatory and had to be strictly followed; the High Court could not relax them. The court, after examining the instructions, held that they were clear and gave specific alternatives which the petitioner had not complied with. Relying on the decisions in Ran Vijay Singh & Ors. v. State of U.P. & Ors. [(2018) 2 SCC 357] and a Supreme Court order in Civil Appeal No.6669 of 2019, the court emphasized that strict adherence to the terms of examination instructions is of paramount importance, and that courts under Article 226 cannot modify or relax such mandatory instructions. The court distinguished a prior single judge order wherein relief was granted for partial non-signing, noting that the same had been stayed by a Division Bench. It also referred to another single judge decision dismissing a similar case for violation. Accordingly, the writ petition was dismissed with no costs, and the rejection of the answer sheet was upheld.
Headnote
A) Service Law - Public Examinations - Mandatory Compliance with Examination Instructions - Tamil Nadu Public Service Commission Instructions - The petitioner, a person with locomotor disability, failed to affix signature or thumb impression on the OMR answer sheet; instructions provided alternatives including leaving blank if unable to use both hands, but petitioner did not establish such inability. Held that the instructions are mandatory and must be strictly complied with; Courts cannot relax them under Article 226. Sympathy or compassion cannot be a ground for directing re-evaluation. The writ petition was accordingly dismissed. (Paras 4-11, 14)
Issue of Consideration
Whether the rejection of the petitioner's OMR answer sheet for not affixing signature or thumb impression, despite instructions allowing alternative methods, is valid, and whether the Court can direct re-evaluation under Article 226 of the Constitution.
Final Decision
The writ petition was dismissed. No costs. The court held that the instructions are mandatory and cannot be relaxed under Article 226. The petitioner's failure to sign or affix thumb impression violated the instructions, and the rejection of the answer sheet was justified.
Law Points
- Legal points not extracted
- Mandatory instructions of examination authorities must be strictly complied with
- High Court cannot modify or relax such instructions under Article 226
- Sympathy or compassion cannot override the mandatory nature of exam rules
- If an error is committed by the authority
- the entire body of candidates suffers
- Rules cannot be changed for a single candidate
