Summary
Some postgraduate medical diploma candidates challenged the digital evaluation of their answer scripts. The Andhra Pradesh High Court called for the scripts, found them improperly evaluated and ordered re-evaluation by fresh examiners. The Supreme Court held that where neither the MCI rules nor the University's rules provide for re-evaluation, a High Court under Article 226 cannot call for answer scripts to decide whether re-evaluation is needed and then order it. The Court disapproved that practice. Courts lack expertise in academic matters, and sympathy plays no part. The University's improved digital evaluation system was also noted. The High Court's orders were set aside. Results already declared after re-evaluation or supplementary examinations, and degrees awarded, were left undisturbed.
Issues
- Whether, in the absence of any provision for re-evaluation, the High Court under Article 226 could call for answer scripts and order their re-evaluation.
Provisions considered
- Article 226, Constitution of IndiaThe writ jurisdiction does not extend to calling for answer scripts and directing re-evaluation where the relevant rules contain no provision for it. (¶¶ 7, 9, 10)
Held
- In the absence of a provision for re-evaluation in the relevant rules, examinees have no right to claim it, courts have no expertise to re-evaluate or scrutinise answer sheets, and interference with examination results breeds uncertainty to the detriment of public interest. (¶¶ 8, 8.1, 8.2, 8.3)
- The practice of High Courts calling for answer scripts to satisfy themselves whether re-evaluation is needed and then directing it, without any provision for re-evaluation, is wholly impermissible and disapproved. (¶ 9)
- The University's digital evaluation system had been improved with instructions and training to examiners and approved by the High Court, and in any case, with no regulation for re-evaluation in the MCI or University rules, sympathy could not justify ordering it. (¶¶ 5.1, 5.2, 10)
- Since results had already been declared after re-evaluation or supplementary examinations and degrees issued, the quashing of the High Court's orders would not disturb them. (¶¶ 3, 4, 11)
Result
Appeals allowed; the judgments of the learned Single Judge and the Division Bench of the Andhra Pradesh High Court ordering re-evaluation set aside, without affecting the results already declared for the original writ petitioners on re-evaluation or in the supplementary examination; no order as to costs.