Karnataka State Law University Has Autonomy To Regulate Its Revaluation Process: HC Rejects Student's Plea Against Evaluation Standards

The Karnataka High Court has dismissed an appeal filed by a Law student challenging an order of the single judge which rejected his petition questioning the re-valuation standards adopted by the Karnataka State Law University.

In doing so the court underscored that in absence of any provision under the University's regulations which provide for revaluation beyond the process already undertaken, the University cannot be directed to conduct revaluation at the student's instance.

A division bench of Chief Justice N V Anjaria and Justice K V Aravind while dismissing A J James's appeal said, “Learned Single Judge's decision is in accordance with the legal framework that grants academic institutions the autonomy to regulate their examination and evaluation processes. The University has adhered to its prescribed revaluation and challenge valuation procedures. Therefore, judicial intervention is not warranted, as the appellant's request for further revaluation is not supported by the University's regulations or by any exceptional circumstances that would justify such intervention.”

James had joined a three years LL.B course at Rajiv Gandhi College of Law, in 2016, which is affiliated to the Karnataka State Law University, Hubballi. He failed in certain subjects and applied for revaluation of the answer scripts and also applied for challenge valuation of a few subjects.

Upon revaluation/challenge valuation, marks in certain subjects improved upward and downward as well. Thus it was claimed by him in the petition that the valuation standards adopted by the University are not up to the mark. He prayed for fresh evaluation of the answer scripts and declare the results.

The appellant alleged that the faculties entrusted with the task of evaluation of answer scripts are not qualified and the medium of education of the evaluators also matters for fair, qualitative and quantitative evaluation of answer scripts. Moreover, the variation exceeding 15% to 20% while revaluation/challenge valuation would evident that the scheme of evaluation needs re-consideration.

The University opposed the plea saying the benefit of revaluation/challenge valuation is provided and the benefit as assessed is extended to the appellant. The University regulations do not provide for further revaluation or any other valuation of answer scripts.

On going through the records the bench noted the appellant availed himself of the option to request revaluation for certain subjects and challenge valuation for others. The University then conducted the revaluation and challenge valuation in accordance with the procedure outlined in its regulations, guidelines, and orders, ensuring that the appellant's requests were handled in accordance with the existing rules.

Rejecting the contention of the appellant the court said “The revaluation and challenge valuation process, as conducted by the University, has already provided a fair opportunity for the appellant to have his marks reassessed. Since the University's regulations and procedures for revaluation were followed in this case, and considering the changes in the appellant's marks were within the scope of the University's established process, the Court does not find sufficient grounds to question or revise the entire valuation system based solely on the results of the appellant's individual revaluation requests.”

Following which it held “In the absence of any provision under the University's regulations to provide for revaluation beyond the process already undertaken, the University cannot be directed to conduct revaluation at the instance of the appellant.”

It added “In the absence of specific provisions in the University's rules and regulations that would permit the revaluation of the appellant's answer scripts beyond the established revaluation and challenge valuation process, learned Single Judge's rejection of the appellant's prayer for revaluation cannot be held incorrect.”

Accordingly it dismissed the appeal.

Appearance: A J Jamesh Appellant party in person.

Advocate R Girish Kumar for Respondents.

Citation No: 2024 LiveLaw (Kar) 504

Case Title: A J James AND Karnataka State Law University & Others

Case No: WRIT APPEAL No.257 OF 2024

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