Case Note & Summary
The Supreme Court of India heard a civil appeal filed by the Uttar Pradesh Subordinate Service Selection Commission against a judgment and order of the Division Bench of the High Court of Judicature at Allahabad dated 20.03.2026. The High Court had allowed a review application and directed the Commission to award one mark to a candidate who had selected Option C in a General Knowledge question in an examination for the post of Village Development Officer. The Commission had published an advertisement on 18.01.2016 inviting applications for 3133 posts of Village Development Officer. A written test was held on 05.06.2016, a provisional answer key was published on 09.06.2016, and a revised answer key was published on 30.06.2016. The result was declared on 18.07.2018, and a supplementary result was published on 26.06.2020. The candidate, Ashok Yadav, filed Writ A No.10221 of 2019 before a Single Judge, seeking a direction to allot one mark for his answer to question 68, which asked which pair was incorrect. The Commission's key selected Option B as correct, while the candidate had selected Option C, contending that Humayunnama was authored by Gulbadan Begum, not Humayun. The Single Judge dismissed the writ petition on the ground of laches and relied on U.P. Public Service Commission through its Chairman v. Rahul Singh. The candidate's intra court appeal was dismissed by the Division Bench on 20.01.2021. Subsequently, a review application was filed, and the impugned order allowed it, holding that an expert report dated 10.08.2020 indicated both Option B and Option C could be correct depending upon the perception of the reader. The High Court directed the Commission to declare the review petitioner's result and the State Government to issue appointment. Before the Supreme Court, the Commission argued that the expert report was equivocal, that the question did not specify authorship as the parameter, and that both phonetically and subject-wise, Option B was the only incorrect pair. The respondent argued that the question appeared in the General Knowledge section, where authorship is relevant, and that Option C was the only incorrect pair because Humayunnama was written by Gulbadan Begum. Alternatively, if no parameter was specified, both B and C could be correct, justifying the award of one mark. The Supreme Court identified the issue as whether the High Court was justified in interfering with the Commission's decision. The Court began its analysis by examining the scope of judicial review in such matters and extracted the principles from Ran Vijay Singh v. State of U.P. The judgment text provided ends during this analysis, and no final decision is recorded in the excerpt. Therefore, the final outcome of the appeal is not mentioned.
Headnote
A) Administrative Law - Judicial Review - Public Examinations - Scope of judicial review over answer keys in public recruitment examinations - No specific statute cited in the excerpt - The Supreme Court examined the limited scope of judicial review in challenges to the correctness of answer keys. It extracted principles from Ran Vijay Singh v. State of U.P.: courts should presume the correctness of key answers, should not re-evaluate or scrutinize answer sheets, academic matters are best left to academics, and in the event of doubt, the benefit should go to the examination authority rather than to the candidate. The Court reiterated that interference is permissible only in rare or exceptional cases where a material error is demonstrated clearly without inferential process of reasoning (Paras 19-20).
Issue of Consideration
Whether the High Court was justified in interfering with Commission's decision to pick Option B as the only correct answer to the concerned question?
Law Points
- Judicial review of answer keys is limited
- courts should presume correctness of key answers
- academic matters best left to academics
- courts should not re-evaluate or scrutinize answer sheets
- in event of doubt benefit should go to examination authority rather than candidate
- interference only in rare or exceptional cases where material error demonstrated clearly
