Summary
The recruitment results were directed to be revised using the Court-appointed experts’ report. The High Court had improperly substituted its own assessment of disputed answers without expert assistance, producing repeated uncertainty. As an exceptional measure under Article 142, appointments already made pursuant to the Single Judge’s directions were protected, and any excess selections were to be accommodated against relevant future vacancies arising up to 31 December 2019. Both High Court judgments were set aside.
Issues
- What limits govern judicial review of examination answers.
- Whether the expert report should govern the revised recruitment results.
- How existing appointments and excess selections should be treated.
Provisions considered
- Articles 226 and 142, Constitution of IndiaApplied narrow review of academic evaluation and used exceptional complete-justice powers to revise results while protecting existing appointments and accommodating excess selections within the stated vacancy period. (¶¶ 20, 21, 22, 23, 24, 25)
Held
- Courts lack the expertise to re-evaluate examination answers themselves. Absent an enabling provision, intervention is confined to clearly demonstrated material error in rare or exceptional cases; answer keys are presumed correct and doubt ordinarily benefits the examining authority. Disputed expert answers should have been referred to another expert panel rather than judicially rewritten. (¶¶ 20, 21, 22)
- The Court-appointed committee’s reasoned recommendations demonstrated that the earlier judicial re-evaluations were inaccurate. The Court exceptionally accepted that report and directed fresh evaluation and publication of results on its basis. (¶¶ 11, 12, 13, 14, 19, 23, 24)
- The Commission and State had to preserve appointments already made pursuant to the Single Judge’s directions. If revised selections exceeded vacancies available at the stipulated recruitment cut-off, the excess candidates were to be accommodated in the relevant cadres against future vacancies arising until 31 December 2019. These were case-specific directions under Article 142 to settle the prolonged dispute. (¶ 24)
Result
Single Judge and Division Bench judgments set aside; appeals disposed of with expert-based re-evaluation, protection of specified existing appointments and accommodation of excess selections against the stated vacancies. No order as to costs.