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Union Public Service Commission & Ors. v. Angesh Kumar & Ors.

Civil Appeal · 2018 INSC 179Decided 20 Feb 2018
Civil Appeal Nos. 6159-6162 of 2013
Justice Adarsh Kumar Goel · Justice Uday Umesh Lalit

Background

Candidates who were unsuccessful in the UPSC Civil Services (Preliminary) Examination, 2010 moved the Delhi High Court seeking disclosure, under the Right to Information Act, of their raw and scaled marks, subject-wise cut-offs, the scaling/moderation methodology, model answers and the results of all candidates. Both the Single Judge and the Division Bench of the High Court directed UPSC to furnish this information, and UPSC (along with some connected RTI appeals against other public authorities) appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that the High Court had failed to balance the right to information against other legitimate public interests recognised under the RTI Act, including the integrity of the examination system, the confidentiality needed to protect examiners, and the efficient use of limited administrative resources, relying on its earlier rulings in CBSE v. Aditya Bandopadhyay and the UPSC evaluation-process concerns documented in Prashant Ramesh Chakkarwar v. UPSC. It held that information such as raw marks in a competitive exam like the Civil Services Examination cannot be ordered disclosed mechanically, and since the High Court's direction had been issued without weighing these competing considerations, the impugned orders were set aside and the underlying writ petitions were dismissed, while leaving the respondents free to make out a proper case before an appropriate forum if they could. The connected civil appeal and the tagged special leave petitions were disposed of in the same terms.

Lesson Learnt

The right to information is not absolute: courts must weigh it against other recognised public interests such as administrative efficiency and the integrity of sensitive processes like examination evaluation, and a blanket direction for disclosure of raw exam marks and evaluation data cannot be issued without that balancing exercise.

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

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