Summary
In appeals concerning six disputed questions in CLAT 2025, the Supreme Court modified the Delhi High Court's directions, ordering that marks be given for two options in one question, that the answer key be corrected in another, and that three questions be deleted, while deprecating the casual manner in which the Consortium of National Law Universities framed the paper and reiterating that courts interfere in academic matters only when academicians act in a way that harms the career prospects of lakhs of students.
Issues
- Whether, and to what extent, the Court should interfere with the Consortium's answer key and the High Court's directions concerning Question Nos. 56, 77, 78, 88, 115 and 116 of CLAT 2025.
- Whether a candidate could answer Question No. 77 on void and voidable agreements from the passage supplied without prior knowledge of the Indian Contract Act, 1872.
Held
- Courts are generally reluctant to interfere in academic matters for want of expertise, but where academicians themselves act in a manner that adversely affects the career aspirations of lakhs of students the Court has no alternative but to interfere. The Court recorded its anguish at the callous and casual manner in which the Consortium framed CLAT questions, recalling that in Disha Panchal a committee had been constituted to look into the conduct of the examination. (¶¶ 4, 5, 6, 8)
- Question No. 56: the passage itself stated that both the State and its residents have a fundamental duty to preserve natural resources, and the Court has repeatedly held that this duty rests on both the State and its citizens. The High Court's conclusion that option (d) alone was correct was set aside; candidates who chose either option (c) or (d) are to receive positive marks and only those who chose (a) or (b) are to receive negative marks. (¶¶ 17, 19, 20, 21, 22)
- Question No. 77: the paper's format supplies basic information in a passage preceding each set of questions, and the passage on void and voidable agreements made it clear that a voidable contract remains valid until rejected by the party at a disadvantage. A candidate applying logic and reason could therefore answer, without prior legal knowledge, that an agreement signed by a minor is voidable. The High Court's direction treating the question as out of syllabus and withdrawn was set aside; option (b) is to receive positive marks and options (a), (c) and (d) negative marks. (¶¶ 27, 28, 29, 30, 31, 32)
- Question No. 78: the Court agreed with the High Court that option (c) is the correct answer and declined to interfere. (¶ 38)
- Question No. 88: there was no significant difference between this question and Question No. 85, which the Consortium had itself deleted on the same material; having deleted Question No. 85 it ought to have deleted Question No. 88 as well. The High Court's direction was set aside and Question No. 88 directed to be deleted. (¶¶ 41, 44, 45)
- Question No. 115: answering it required a detailed mathematical analysis not expected in an objective test. The High Court's direction awarding marks only to candidates who attempted it was set aside and the question directed to be deleted. Question No. 116 was based on the information in Question No. 115 and had to be deleted as a necessary corollary and, to put all candidates on an equal footing, from all four sets, the Consortium having fairly offered to withdraw it across sets. (¶¶ 48, 49, 50, 53, 54, 55, 56, 57)
Result
Appeals and intervention/impleadment applications disposed of by modifying the High Court's judgment dated 23 April 2025 to the above extent; the Consortium directed to amend the answer key, revise the marksheet, re-publish the final list of candidates forthwith and commence counselling within two weeks; pending applications disposed of.