Dr. NTR University of Health Sciences vs. Dr. Yerra Trinadh & Others
Background
Post-graduate diploma students of Dr. NTR University of Health Sciences were unhappy with how their digitally evaluated answer scripts were marked and got a Single Judge of the Andhra Pradesh High Court to order re-evaluation by fresh examiners. A Division Bench of the High Court upheld that order. The University appealed to the Supreme Court, arguing there was no rule allowing re-evaluation at all, so the High Court had no business ordering it under its writ powers.
Decision Breakdown
The Supreme Court held that, in the absence of any specific provision for re-evaluation in the applicable rules, a High Court exercising writ jurisdiction under Article 226 cannot direct re-evaluation of answer scripts merely by calling for the record and forming its own view: this is settled by earlier rulings including Pramod Kumar Srivastava and Ran Vijay Singh. The Court also noted the University's digital evaluation system had since been reviewed and approved by the High Court in a later case. Both the Single Judge's and Division Bench's orders directing re-evaluation were quashed. However, since the re-evaluated results had already been declared and degrees issued to the students years earlier, the Court protected those already-declared results from being disturbed.
Lesson Learnt
Courts will not order re-evaluation of exam answer sheets unless the governing rules expressly provide for it: students seeking re-evaluation must rely on an actual regulation, not just dissatisfaction with their marks.