Case Note & Summary
The University of Madras filed an intra-court appeal against a writ order that directed the University to round off the respondent's marks from 59.91% to 60% to secure First Class. The respondent, an I.P.S. Officer, had sought this relief through a writ petition, which was granted by the writ court based on the precedent set in the case of State of U.P. Vs. Pawan Kumar Tiwari. The University contended that rounding off marks was not permissible as per guidelines and cited another case where the Supreme Court ruled against such practices. The court emphasized that the evaluation of answer sheets is the domain of experts and that judicial intervention in marking could lead to unfair advantages and disrupt the examination process. The court ultimately decided that the writ order could not be sustained, set it aside, and allowed the appeal, closing the connected civil miscellaneous petition.
Headnote
A) Education Law - Rounding Off Marks - Judicial Review Limitations - Article 226 of the Constitution of India - The court held that rounding off marks awarded by the University is beyond judicial review powers, as it could prejudice other candidates and alter examination schemes. Courts should exercise restraint in matters of evaluation and awarding marks (Paras 7-9).
Issue of Consideration
Whether the High Court can enhance marks awarded by the University and apply the law from the case of Pawan Kumar.
Final Decision
The High Court set aside the writ order dated 08.07.2022 passed in W.P.No.11821 of 2022, allowing the appeal and closing the connected civil miscellaneous petition.
Law Points
- Judicial review
- Rounding off marks
- Evaluation of answer sheets
- Article 226 of the Constitution of India
Case Details
2026 LawText (MAD) (09) 197
S.M.Subramaniam, Krishnaswamy Govindarajan
Mr.T.Pushkin Rajkumar, Mr.M.Ravi
The University of Madras, The Controller of Examinations
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Nature of Litigation
Intra-court appeal against a writ order regarding marks awarded in an examination.
Remedy Sought
The University of Madras sought to set aside the writ order that directed rounding off marks.
Filing Reason
The respondent filed a writ petition for rounding off marks to secure First Class.
Previous Decisions
The writ court had allowed the petition based on a precedent from the Supreme Court.
Issues
Whether the High Court can enhance marks awarded by the University.
Whether the application of law from the case of Pawan Kumar can be relied upon for granting relief.
Submissions/Arguments
The respondent argued that rounding off would not prejudice other candidates.
The University contended that rounding off marks is not permissible as per guidelines.
Ratio Decidendi
The court held that judicial review does not extend to altering marks awarded by educational institutions, as it could lead to unfair advantages and disrupt the examination process.
Judgment Excerpts
The University of Madras preferred the present intra-court appeal under Clause 15 of the Letters Patent challenging the writ order dated 08.07.2022.
The court emphasized that the evaluation of answer sheets is the job of the domain expert.
In the event of rounding off or enhancement of marks, would cause prejudice to other candidates.
Procedural History
The University of Madras filed an intra-court appeal against the writ order issued on 08.07.2022 in W.P.No.11821 of 2022.
Acts & Sections
- Constitution of India: Article 226
