Dr. B R Ambedkar University, Agra vs. Devarsh Nath Gupta & Ors.
Background
An MBBS student was declared to have failed his First Professional examination after scoring just 6 out of 50 marks in the Physiology Paper-II, despite performing reasonably well overall. When the university did not respond to his requests for re-checking, he approached the Allahabad High Court. The High Court had the answer sheet independently re-evaluated by three separate examiners, all of whom awarded far higher and mutually consistent marks (19, 20 and 21), confirming that the original examiner appeared to have barely looked at three of the five answers. The High Court not only directed the university to award the student the average of these marks, but went further, imposing Rs. 1 lakh in costs on the university, ordering it to entertain re-evaluation requests from any student from the preceding three years even though the university's own statute had no such provision, and directing that the judgment be sent to state education secretaries to ensure examiners generally be deployed "in a reasonably efficient manner."
Decision Breakdown
The Supreme Court reaffirmed the settled position that courts should not ordinarily order re-evaluation of subjective, descriptive-type exam answers where the governing statute or rules do not provide for it, since assessing academic answers is not a judicial function. However, given the unusual facts here, the original examiner appeared to have simply skipped scoring three answers altogether, the Court declined to disturb the specific relief already granted to this one student. It struck down everything else the High Court had ordered: the Rs. 1 lakh cost on the university was found disproportionate; the blanket direction opening up re-evaluation to any student from the past three years, despite the University's statute containing no such provision, was held to have no logical basis and to improperly treat one examiner's isolated lapse as grounds to reopen an entire institution's results; and the vague direction to state authorities about "reasonably efficient" deployment of examiners was found incapable of certain implementation and therefore not a proper judicial mandamus. The appeal was allowed in part, only the correction of this student's own marks was left standing, and all the broader systemic directions were annulled, with no order as to costs.
Lesson Learnt
Even where a court is right to step in over one clearly botched exam evaluation, the relief it grants must stay tied to the specific facts and parties before it: a single examiner's failure cannot be used to reopen an institution's results system-wide or to issue vague institutional directives, and courts generally cannot order re-evaluation of subjective answer papers unless the governing rules themselves allow for it.