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Ran Vijay Singh & Ors. v. State of U.P. & Ors.

Civil Appeal · 2017 INSC 1209Decided 11 Dec 2017
Civil Appeal No. 367 of 2017
Justice Madan B. Lokur · Justice Deepak Gupta

Background

Over 36,000 candidates sat a 2009 written examination for Trained Graduate Teacher posts conducted by the U.P. Secondary Education Services Selection Board. After the results were declared, some unsuccessful candidates went to the High Court claiming errors in seven key answers; a Single Judge personally re-evaluated those answers (despite there being no rule permitting re-evaluation) and ordered the answer sheets of all 36,000+ candidates re-checked, which produced a second set of results. The Division Bench, hearing appeals against this, sent some of the disputed answers to an outside Expert Committee and ordered yet a third re-evaluation, leading to a third set of results: eight years after the original exam, with no finality for the originally selected candidates (the present appellants).

Decision Breakdown

The Supreme Court strongly disapproved of both lower-court interventions, reaffirming settled law that courts have no expertise to second-guess examination key answers and should not order re-evaluation unless a rule specifically permits it, or unless an error is demonstrated with certainty rather than through "an inferential process of reasoning." Even though the Single Judge's and Division Bench's interventions were legally improper, the Court found that nullifying the extensive machinery already set in motion (the completed third evaluation) was impractical after eight years, so it adopted a "middle path": the third and final set of results would be declared and used going forward, but candidates who had already been working as teachers under earlier results would keep their jobs even if later found unsuccessful, and any newly-selected candidates from the third round would be given supernumerary posts without back-dated benefits.

Lesson Learnt

Courts should almost never substitute their own judgment for that of examination authorities on the correctness of exam answers unless a rule allows re-evaluation or an error is undeniable, and once litigation drags out an exam's finality for years, courts may craft a practical "no-one worse off" compromise rather than restart the process from scratch.

Official source (sci.gov.in)View Judgment (PDF)

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