Expert Committee's Answer Key Can Only Be Interfered With If Demonstrably Wrong, Must Be Assumed To Be Correct In Case Of Ambiguity: Rajasthan HC

Rajasthan High Court has held that interference by the Court with regard to the correctness of an answer key published by the expert committee is permissible only if it is demonstrated wrong, without any inferential process of reasoning or by a process of rationalization and only in rare or exceptional cases.

Otherwise, it was stated that the Court should presume the correctness of the answers and proceed on that assumption and in the event of a doubt, the benefit should go to the examination authority, rather than to the candidate.

The division bench of Chief Justice Manindra Mohan Srivastava and Justice Shubha Mehta was hearing a bunch of appeals filed in relation to a dispute that arose regarding the correctness of an answer in the examination for the post of Patwari.

It was the case of the appellants that even though the scope of judicial review regarding the issue was very limited, the answer key finalized by the expert committee was demonstrably wrong and hence required interference from the Court.

On the other hand, it was argued by the respondents that the Court should not enter into giving its opinion on what could be the correct answer except in very rare circumstances where without any detailed process of rationalizations, the answer key was established as demonstrably wrong.

To ascertain the position of law, the Court referred to certain Supreme Court cases on this issue. In the case of Kanpur University v Samir Gupta it was held that the answer key should be assumed to be correct unless it was proved wrong, not by an inferential process of reasoning or by a process of rationalization. It must be clearly demonstrated to be wrong, i.e. it must be such that no reasonable men well-versed in the subject would regard it as correct. It was said:

“There is an assumption about the key answers being correct and in case of doubt, the court would unquestionably prefer the key answer…Regarding the key answers in respect whereof the matter is beyond the realm of doubt, this Court has held that it would be unfair to penalise the students for not giving an answer which accords with the key answer, that is to say, with an answer which is demonstrated to be wrong.”

Further reference was made to the case of Uttar Pradesh Public Service Commission, through its Chairman and Another v Rahul Singh and Another in which the Supreme Court analysed all the precedents on the issue and propounded certain principles. It was held that the law was well settled that the onus was on the candidate to demonstrate that the answer key was incorrect and that it was a glaring mistake which was apparent without any inferential process of reasoning or rationalization. It was further held that the courts need to exercise great restraint in such matters and should be reluctant in entertain a plea challenging the correctness of the answer key. The court held:

“Judges cannot take on the role of experts in academic matters. Unless, the candidate demonstrates that the key answers are patently wrong on the face of it, the courts cannot enter into the academic field, weigh the pros and cons of the arguments given by both sides and then come to the conclusion as to which of the answers is better or more correct.”

In the background of this analysis, the Court stated that the complaints regarding the answer key have to be examined by the committee of experts and if in the opinion of the committee, the answer key was demonstrably wrong, the answer given by the candidates was required to be reassessed. It was further held that the scope of judicial review was limited to exceptional cases where the Court finds that model answers were demonstrably wrong on the face of it without involving the inferential process of reasoning or a process of rationalization.

It was stated that the court could not assume the role of an expert to take a different decision than that of the expert committee particularly when the latter decision was based on an authentic text. In case of doubt regarding the answer, the benefit of the doubt should be given to the expert committee by assuming their answer to be the correct one.

In this light, on the facts of the present case, the Court observed that the answer to the disputed question was a historical fact on which there was no unanimity. Since the decision of the expert committee was based on authentic texts, the Court held that it should be treated as the correct answer. Accordingly, the appeals were dismissed.

Title: Mahendra Kumar Jat & Ors. v State of Rajasthan & Ors.

Citation: 2024 LiveLaw (Raj) 163

Click Here To Read/Download Order