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The State of Tamil Nadu & Anr. v. A. Kalaimani & Ors.

Civil Appeal · 2019 INSC 884Decided 8 Aug 2019
Civil Appeal Nos. 6190-6201 of 2019
Justice L. Nageswara Rao · Justice Hemant Gupta

Background

The Tamil Nadu Teachers Recruitment Board held a written exam in 2017 to select Lecturers for Government Polytechnic Colleges. After the results came out, a complaint alleged large-scale tampering of OMR answer sheets, and an investigation found that marks of 196 candidates had been fraudulently altered by an employee of the evaluation agency in exchange for money. The Board cancelled the entire examination rather than just the tainted results, which was challenged in multiple writ petitions before the Madras High Court with conflicting outcomes, eventually reaching a Division Bench that ruled in favour of the candidates and restored the process (minus only the 196 tainted candidates).

Decision Breakdown

The Supreme Court set aside the Division Bench's ruling and restored the Board's decision to cancel the entire examination. It held that when there is credible material showing large-scale malpractice pervading an examination, the authority conducting it is entitled to cancel the whole process rather than being confined to removing only the identified wrongdoers, and that courts exercising judicial review should not second-guess the sufficiency of such material if the decision was bona fide. It also criticised a High Court Single Judge for taking a view contrary to another coordinate-strength Single Judge's earlier ruling on the same issue instead of referring the conflict to a larger Bench.

Lesson Learnt

When an examination's integrity is genuinely compromised by large-scale fraud, the conducting authority can cancel the entire exam, even if that inconveniences innocent candidates, rather than being forced to surgically segregate only the proven wrongdoers.

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

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