Summary
The Court upheld normalization of marks at the written-examination eligibility stage of Uttar Pradesh police recruitment conducted through different question papers over multiple sittings. The amended rules empowered the Board to prescribe procedure, and normalization had been announced before the examination. Marks meant normalized scores both for the minimum subject-wise qualification and final merit, avoiding inconsistent treatment of candidates facing different papers. The High Court’s contrary decision was set aside and the February 2019 results restored for implementation. Possible future concessions for affected candidates were left to the State.
Issues
- Whether the Board could normalize marks when determining minimum written-examination eligibility rather than only at final merit-list preparation.
- Whether earlier scaling precedents or summary dismissal of a related special-leave petition barred that approach.
- What relief should follow for the declared results and candidates later disqualified after normalization.
Provisions considered
- Rule 15(b) and (e), Uttar Pradesh Sub-Inspector and Inspector (Civil Police) Service Rules, as amended in 2015Procedural empowerment supported normalization at the written-test stage; marks carried the same normalized meaning for eligibility and merit. (¶¶ 14.3, 26-31, 43-53)
- Articles 136 and 141, Constitution of IndiaSummary non-speaking refusal of special leave did not affirm the underlying judgment, declare binding law or attract merger. (¶ 23)
Held
- The amended rules removed the former uniform-examination procedure and empowered the Board to hold different sittings and determine examination procedure. The normalization notice preceded the examination. Different papers across twenty-nine sittings required a common evaluative scale; the earlier single-examination cases did not control this distinct situation. (¶¶ 25-31, 39-43)
- The same examination marks governed both subject-wise eligibility and final merit. Restricting normalization to final ranking would exclude candidates who qualified on the common scale while retaining those whose normalized scores fell below the required minimum. Eligibility continued through recruitment, and normalized scores therefore applied at both stages. (¶ 45-53)
- Sanjay Singh did not impose an inflexible prohibition on normalization. Choice of a suitable evaluative method depends on the governing rules and circumstances, with due regard for expert decisions. No mala fides or lack of bona fides was alleged in this process. (¶¶ 33-43, 53)
- The non-speaking dismissal at the special-leave stage in a related challenge did not affirm the High Court’s interpretation or create merger or a binding declaration of law. The present appeals could be determined independently. (¶ 23)
- The results declared on 28 February 2019 were to be implemented expeditiously. For candidates allowed to proceed on raw marks but later disqualified on normalized scores, the State could consider weightage or age relaxation in the next selection; the Court did not direct their appointment or mandate such concessions. (¶ 54-55)
Result
Appeals allowed; High Court judgment set aside; results of 28 February 2019 to be implemented expeditiously; possible future concessions left to State consideration; no costs.