The Supreme Court has held that courts should ordinarily presume the correctness of answer keys prepared by examining authorities. The Supreme Court Answer Key ruling makes it clear that judicial interference is justified only when an error is glaring and apparent. Such an error must be identifiable without inferential reasoning.
A bench of Justice Manoj Misra and Justice Vijay Bishnoi made the observation while allowing an appeal filed by the Uttar Pradesh Subordinate Service Selection Commission (UPSSSC). The Court set aside an Allahabad High Court order that granted an additional mark to a candidate in a Village Development Officer recruitment examination.
The High Court had also directed the Commission to prepare a fresh recommendation. It further directed the Uttar Pradesh government to appoint the candidate.
Dispute Over Answer in UPSSSC Examination
The Commission had advertised vacancies for Village Development Officers. It subsequently declared the examination results based on a revised answer key.
The dispute arose from a question asking candidates to identify an incorrectly matched pair. Four options linked historical chronicles with their subjects or authors.
According to the Commission’s answer key, Option B — Shahjahannama – Mohd Tahir — was the correct response because it constituted the incorrect pair.
The respondent candidate, however, selected Option C — Humanyunnama – Humayun. He argued that this was the incorrect pair because Gulbadan Begum, and not Humayun, authored Humayunnama.
High Court Initially Dismissed Candidate’s Challenge
The candidate approached the Allahabad High Court by filing a writ petition. A Single Judge dismissed the petition on the ground of laches.
Thereafter, the Division Bench dismissed his appeal.
The candidate then sought review of the Division Bench’s decision. During the review proceedings, the Division Bench relied upon an expert opinion.
The expert indicated that both options could be correct “depending upon the perception of the reader.”
Based on that opinion, the Division Bench reversed its earlier position. It directed the Commission to award the candidate one additional mark. It also ordered the Commission to prepare a fresh recommendation. Further, it directed the Uttar Pradesh government to grant him appointment.
The Commission challenged the review order before the Supreme Court.
Commission Defends Option B
Before the Supreme Court, the Commission argued that the expert report did not conclusively support the candidate.
According to the Commission, the report never identified Option C as the only correct answer. It also argued that the question did not expressly make authorship the basis for matching the options.
Therefore, the Commission submitted that a commonsense interpretation supported Option B as the mismatched pair.
The respondents presented a different interpretation. They pointed out that the question appeared under the “General Knowledge” section rather than the “General Intelligence Test” section.
On that basis, they argued that authorship was the more appropriate parameter for testing general knowledge. Consequently, they submitted that Option C should have been accepted. Alternatively, they argued that both Options B and C should be treated as correct.
The respondents relied on Siddhi Sandeep Ladda v Consortium of National Law Universities. They argued that courts retain the power to intervene when academic decisions adversely affect candidates’ career prospects.
Supreme Court Frames the Issue
The Supreme Court framed the central question as:
“whether the High Court was justified in interfering with Commission’s decision to pick Option ‘B’ as the only correct answer to the concerned question?”
The bench then considered the established principles governing judicial review of examination answer keys.
It relied on Ran Vijay Singh v State of UP and UP Public Service Commission v Rahul Singh.
The Court reiterated that courts should presume an answer key to be correct. When doubt remains, the examining authority rather than the candidate should receive its benefit.
Constitutional courts, the bench observed, “must exercise great restraint” while considering challenges to answer keys.
Accordingly, a candidate carries the burden of establishing a mistake that is “totally apparent.” Such an error should not require an “inferential process or reasoning” to identify.
Commission’s Approach Was Not Arbitrary
The Supreme Court then examined the disputed question.
The bench noted that the question did not prescribe a particular parameter for determining the incorrect pair. Therefore, the Commission’s approach of matching each book with its subject could not be characterised as arbitrary or irrational.
The Court described this as a “commonsense approach.”
The bench also examined the expert report that formed the basis of the High Court’s review order.
According to the Supreme Court, the report did not categorically state that Option C alone was correct. Instead, its conclusion depended on the method used to interpret the question.
If authorship formed the basis of comparison, Option C would constitute the incorrect pair. However, if candidates matched each book according to its subject, Option B would be the correct response.
Therefore, the expert report did not establish that the Commission had incorrectly chosen Option B.
Candidate Applied Inferential Logic, Court Says
The Supreme Court also addressed the respondent’s reliance on authorship.
It observed that the candidate encountered difficulty because he read authorship into the question as the governing parameter. However, the question itself did not expressly indicate such a requirement.
The bench stated that the candidate had made an “assumptive mistake.” It held that neither the question nor the examining authority could bear responsibility for that assumption.
The Court acknowledged that it might appear as though the candidate was “being punished for having knowledge about a historical fact.”
However, this could not determine the scope of judicial review. Instead, courts must examine whether an alleged error is obvious enough to require no inferential reasoning.
Court Rejects General Knowledge Argument
The Supreme Court also rejected the respondents’ argument based on the placement of the question in the examination paper.
The respondents argued that authorship should determine the answer because the question appeared in the General Knowledge section.
The bench found no force in that submission. It held that such an interpretation rested on an assumption rather than the wording of the question itself.
The Court emphasised:
“A question is to be understood as it stands and not what it ought to have been.”
High Court Overstepped Review Jurisdiction
Ultimately, the Supreme Court Answer Key decision found no glaring error in the disputed question or the Commission’s selection of Option B.
The Court concluded that the Allahabad High Court had “clearly overstepped its jurisdiction” by interfering with the answer key. It particularly noted that the High Court had done so while exercising review jurisdiction.
The Supreme Court further observed that the expert report did not conclusively identify Option B as incorrect. It also found that the question did not expressly establish authorship as the governing principle.
Accordingly, the Court held that neither the question nor the answer was patently incorrect. It found no justification for the High Court’s interference and allowed the Commission’s appeal.
