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Service & Administrative LawSupreme Court of India

U.P. Public Service Commission v. Manoj Kumar Yadav & Anr.

Civil Appeal · 2018 INSC 157Decided 16 Feb 2018
Civil Appeal No. 2326 of 2011
Justice S.A. Bobde · Justice L. Nageswara Rao

Background

The U.P. Public Service Commission conducted the 2004 "Backlog" and "P.C.S." recruitment examinations, which included compulsory subjects (General Studies, Hindi, English Essay) and optional subjects chosen from 33 options. Candidates challenged the results before the Allahabad High Court, which quashed them, holding that the Commission's use of a statistical "scaling" method (rather than "moderation") to adjust marks, including for the compulsory subjects, was arbitrary, relying on the Supreme Court's earlier ruling in Sanjay Singh v. U.P. Public Service Commission (2007).

Decision Breakdown

The Supreme Court agreed with the High Court that scaling (appropriate only to compare marks across different optional subjects) should not have been applied to the compulsory subjects, which were common to all candidates and should instead have used moderation to correct for examiner variability, so the Commission's evaluation method was indeed arbitrary. However, the Court declined to let the High Court's remedy stand: ordering the results to be redeclared afresh would have displaced candidates who had already been selected and had been working in their posts for roughly ten years under an interim Supreme Court order, through no fault of their own. Exercising its power to mould relief to do complete justice, and noting the examinations had been conducted under a method then-approved by an earlier Supreme Court ruling (Subhash Chandra Dixit), the Court made its finding of illegality prospective only, upholding that the scaling method was wrong in principle, but refusing to disturb the existing appointments.

Lesson Learnt

Courts can declare a government process (such as an exam evaluation method) legally flawed while still protecting people who already relied on its outcome in good faith for years: a finding that something was done wrongly does not automatically mean everyone affected must be undone.

U.P. Public Service Commission v. Manoj Kumar Yadav & Anr. – Legal Case Shots | LegalAware