Uttar Pradesh Subordinate Service Selection Commission v. Ashok Yadav & Ors.
Background
The UP Subordinate Service Selection Commission held a written test in 2016 for 3,133 posts of Village Development Officer. A candidate disputed the Commission's answer to a General Knowledge question asking which of four book–person pairings was "incorrect" (e.g., Baburnama–Babur), arguing that option C should be correct because "Humayunnama" was actually authored by Gulbadan Begum, not Humayun, rather than option B (the Commission's chosen answer). His writ petition was dismissed by a Single Judge for delay and on settled law that courts should be reluctant to second-guess answer keys, and an intra-court appeal was also dismissed. However, a subsequent review petition was allowed by the High Court's Division Bench, based on an expert opinion suggesting both B and C could be correct depending on interpretation, and the Commission was directed to award the extra mark and recommend the candidate for appointment.
Decision Breakdown
The Supreme Court reaffirmed the settled legal principle (from Ran Vijay Singh v. State of U.P. and U.P. Public Service Commission v. Rahul Singh) that courts can interfere with an examination answer key only where the error is so glaring and apparent that it requires no inferential reasoning to detect, with the benefit of any doubt going to the examining body, not the candidate. Examining the disputed question itself, the Court found it did not specify whether pairing was to be done by "authorship" or by "subject" (whom the book was about); using a commonsense, subject-wise approach, option B was a reasonable answer since Shahjahannama does not describe Mohd. Tahir, whereas all other options genuinely relate the book to its named person. The expert report relied on by the High Court did not declare option B wrong. It merely noted that option C would follow if one used an authorship-based logic instead, meaning the report was equivocal, not a determination of any glaring error. Since the question and the Commission's chosen answer were not patently or glaringly incorrect, the High Court had overstepped its jurisdiction, especially in review proceedings, by substituting its own interpretation for the Commission's reasonable one. The Supreme Court allowed the appeal, set aside the High Court's order, and dismissed the candidate's original writ petition.
Lesson Learnt
Courts will only strike down or alter an examination authority's answer key when the error is glaringly obvious without any need for inference or interpretation. A plausible alternative reading of an ambiguous question, however reasonable, is not enough to override the examining body's chosen answer, and candidates bear the burden of proving a clear, undeniable mistake.