Supreme Court Ruling on a Contentious Exam Question
In a recent legal development, the Supreme Court of India was tasked with resolving a dispute concerning a single mark in a state recruitment examination. The case involved the Uttar Pradesh Subordinate Service Selection Commission (UPSSSC) and a candidate who contested the Commission’s interpretation of a general knowledge question. This legal battle is documented in the case of UPSSSC v. Ashok Yadav.
The Examination and Dispute
The controversy stemmed from a 2016 examination conducted by the UPSSSC to fill 3,133 Village Development Officer positions. Among the questions asked, candidates were required to identify the incorrectly matched pair from several options, which included: Baburnama–Babur, Shahjahannama–Mohammad Tahir, Humayunnama–Humayun, and Tuzuk-e-Jahangiri–Jahangir. The UPSSSC designated “Shahjahannama–Mohammad Tahir” as the incorrect match based on the subject-wise pairing of books with the historical figures they are about.
A candidate disagreed, selecting “Humayunnama–Humayun” as incorrect, arguing that the book was authored by Gulbadan Begum, not Humayun. The candidate claimed entitlement to an additional mark, leading to a legal challenge against the Commission’s interpretation.
Supreme Court’s Analysis and Decision
The matter was escalated to a Bench comprising Justices Manoj Misra and Vijay Bishnoi of the Supreme Court. The Court upheld the Commission’s original answer, reasoning that the exam question did not specify authorship as the criterion for the pairing. The Court found the Commission’s interpretation plausible and declined to intervene on behalf of the candidate.
Justice Bishnoi noted the peculiar outcome wherein the candidate’s historical knowledge seemingly worked to his detriment, yet emphasized that such knowledge did not warrant judicial interference. The Court reiterated that judicial review of exam answer keys should be limited to instances of glaring errors.
The Court further stated, “In the event of a mere doubt about the correctness of the question or the answer, the benefit should go to the examining body and not to the candidate.” The candidate’s request for an additional mark was ultimately denied.
Previous Court Proceedings
Initially, the candidate approached the High Court seeking an extra mark. A single judge dismissed this plea, but a Division Bench later awarded the mark, influenced by an expert report that acknowledged multiple interpretations of the question. The UPSSSC challenged this decision, prompting the Supreme Court’s review.
The expert report, utilized by the Allahabad High Court, suggested that if authorship was the criterion, “Humayunnama–Humayun” would be incorrect. However, if matching was based on the subjects of the books, “Shahjahannama–Mohammad Tahir” was inaccurately paired. The Supreme Court concluded that the Commission’s choice was not erroneous, and the candidate had mistakenly inferred an unstated condition.
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Conclusion and Legal Representation
The Supreme Court’s decision favored the UPSSSC, overturning the High Court’s ruling and dismissing the candidate’s plea. Senior Advocate PS Patwalia represented the UPSSSC, with a team of advocates including Talha Abdul Rahman and Vibha Swaminathan. Senior Advocate Sudhir Kumar Saxena and other legal representatives appeared for various respondents.
