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Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

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Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Service & Administrative LawSupreme Court of India

Commissioner of Police & Anr. v. Umesh Kumar

Civil Appeal · 2020 INSC 578Decided 7 Oct 2020
Civil Appeal No. 3334 of 2020
Dr. Justice D.Y. Chandrachud · Justice Indira Banerjee

Background

Delhi Police advertised 523 constable vacancies in 2013. After a written exam was held and results declared, it was found that a bonus mark for height had not been correctly applied to some candidates, so results were recompiled. Separately, serious errors were later discovered in the official "model answer key" used to evaluate the exam, errors affecting 45 of 100 questions in one series of the question paper, which led to the entire examination (for that series) being treated as flawed and a revised result being issued before any appointments were made. Candidates who had initially appeared selected under the OBC category, but fell below the cut-off after the revised result, went to the Delhi High Court, which directed Delhi Police to appoint them anyway. Delhi Police appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that once an official answer key is shown to be substantially defective, any result generated using it is unreliable, and correcting the result before appointments are made is not just permissible but necessary to protect the fairness of the process for all candidates, not only those who had initially appeared to succeed. Since the revised, corrected result was declared before the respondents were actually appointed, they had no vested right to insist on appointment based on the earlier, flawed result. The Court distinguished this from cases where officials had already been appointed and working for years, where removing them later could be unjust. It set aside the High Court's directions and dismissed the respondents' writ petitions, confirming that the respondents did not qualify under the corrected result.

Lesson Learnt

A selection result based on a demonstrably erroneous answer key can be corrected and revised even after provisional results are announced, so long as no appointments have yet been made: candidates do not acquire a permanent right to an appointment based on a flawed evaluation process.

Commissioner of Police & Anr. v. Umesh Kumar – Legal Case Shots | LegalAware