The Delhi High Court emphasized that courts must intervene if an official answer key contains a clear error that, if left uncorrected, would lead to injustice. This ruling came during a Letters Patent Appeal filed by the Staff Selection Commission (SSC) challenging a Single Judge’s decision regarding a disputed question in the 2023 Combined Graduate Level Examination Tier-II (CGLE). The question involved determining how many meaningful words could be formed using the letters O, K, E, and Y. While Respondent candidates identified only “YOKE” as correct, SSC contested this, leading the Single Judge to rule that informal usages like “OKEY” should be excluded. The Division Bench upheld the Single Judge’s decision, stressing the court’s duty to correct demonstrably wrong answers to prevent injustice.
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NEW DELHI: The Delhi High Court emphasized that if it finds an answer provided in an official answer key to be incorrect, and leaving it unchanged would result in injustice, it must intervene to rectify the situation.
The Court observed that while the law advocates a cautious approach, it should never be so restrained that it allows injustice to go unaddressed. This ruling came in the context of a Letters Patent Appeal filed by the Staff Selection Commission (SSC) challenging a decision by a Single Judge in a Writ Petition.
The Division Bench, comprising Justice C. Hari Shankar and Justice Sudhir Kumar Jain, reiterated the importance of judicial intervention in cases of clear errors in examination answer keys.
The bench noted-
“If the Court is satisfied that the answer provided in the impugned answer key is obviously incorrect, so that allowing the answer to remain would result in injustice, the Court has necessarily to step in and set aright the situation. Any judge who, perceiving obvious injustice taking place before him, professes inability to interfere, breaches his solemn oath of office. Howsoever circumspect an approach the law may advocate, the approach can never be so circumspect as would allow injustice to occur, unredressed.”
The Case at Hand: Dispute Over ‘Meaningful Words’
The key issue in the case revolved around a question in the examination that required candidates to determine how many “meaningful words” could be formed from the letters O, K, E, and Y. The Respondent candidates had marked the correct answer as ‘one‘, stating that the only meaningful word that could be formed from these letters was ‘YOKE‘.
As per the answer key, the answer was ‘two‘. The SSC experts examined the answer and suggested that the words formed could be ‘YOKE‘ and ‘OKEY‘. They asserted that it was an informal variation of ‘OKAY‘ used “in a casual context”.
The respondents candidates asserted that ‘YOKE‘ was the sole meaningful word, while another possible word, ‘OKEY‘ was dismissed as informal or colloquial usage.
The Single Judge supported this view, ruling that the question clearly intended to exclude informal language, colloquial expressions, or slang terms.
The ruling emphasized that only words recognized as “meaningful English usage” would be valid, stating that-
“the only meaningful word which could be formed from the letters O, K, E, and Y was ‘YOKE,’ and ‘OKEY’ was merely a rare informal usage.”
The Court, while affirming the Single Judge’s decision, observed that in cases where the provided answer is clearly incorrect, and any reasonable individual could determine its inaccuracy, the suggested answers given by experts can indeed be questioned and revised by the judiciary.
The judgment further stated-
“in cases, where the answer is demonstrably wrong and any reasonable man is able to rule out the correctness, the suggested answers of experts can be interfered with by the Courts.”
This principle supports the idea that students should not be unfairly penalized for not selecting an incorrect answer.
The Court also recognized that judicial intervention in academic matters is generally limited. However, in rare and exceptional situations, it acknowledged that courts may intervene even after subject experts have established the accuracy or inaccuracy of answers, but only to a “limited extent.”
As the Court noted-
“in few rare and exceptional cases, the Courts can interfere even after the subject experts have determined the correctness or incorrectness of answers in the answer keys, however, to a ‘limited extent.'”
This judgment highlights the delicate balance courts must maintain when dealing with academic matters, particularly in competitive examinations, where the potential for unfairness in marking can have significant consequences for candidates.
It underscores that while expert judgment is usually respected, there are circumstances where judicial scrutiny is necessary to prevent injustice.
BACKGROUND
The Staff Selection Commission (SSC) conducted the Combined Graduate Level (CGL) Examination Tier-II, 2023 for recruiting candidates to various civil service positions under the Union Government. However, certain candidates (the Respondents) challenged the accuracy of the official answer key, bringing the matter before a Single Judge for review.
The Respondents raised concerns about specific answers listed in the answer key, claiming that some were incorrect. They contended that rectifying these wrong answers would result in a significant change in their final score. According to the candidates, making the corrections they suggested would earn them an additional 21 marks, which could substantially impact their final ranking and selection prospects. The total number of disputed questions amounted to seven.
Among the contested questions, one involved forming a meaningful word using the letters O, K, E, and Y. The official answer key indicated that the number of meaningful words that could be formed from these letters was ‘two‘. Upon review, the SSC experts explained that the words in question were ‘YOKE‘ and ‘OKEY‘. The experts argued that while ‘YOKE’ was widely accepted, ‘OKEY‘ was an informal variation of ‘OKAY‘ used “in a casual context.”
The Single Judge, after reviewing the case, disagreed with the inclusion of ‘OKEY‘ as a valid answer. The Judge clarified that the question’s intent was to focus on standard and formal word usage, not on colloquial or informal variations. In the Judge’s view, ‘OKEY‘ did not meet the criteria for “meaningful English usage”, stating that the only proper word formed from these letters was ‘YOKE‘. The Judge ruled that ‘OKEY‘ was merely a rare informal usage and not acceptable for the examination’s purpose.
Thus, the Judge permitted a correction in the answer to this single question while rejecting the candidates’ challenges regarding the other six disputed questions.
Dissatisfied with the Single Judge’s Order, which was passed on 16th February 2024, the Staff Selection Commission filed a Letters Patent Appeal before the Division Bench. The SSC sought further review of the decision, specifically concerning the interpretation of what constitutes a “meaningful word” and the legitimacy of ‘OKEY‘ as an answer.
This legal dispute highlights the importance of precision and clarity in competitive examinations, where even a single mark can significantly alter the outcome for candidates.
Limited Judicial Intervention in Examination Disputes
The Court also acknowledged that while judicial intervention in academic matters should be rare, it can be justified in exceptional cases where an answer key is clearly incorrect.
It was held that-
“in few rare and exceptional cases, the Courts can interfere even after the subject experts have determined the correctness or incorrectness of answers in the answer keys, however, to a limited extent.”
In the case at hand, the respondents challenged seven answers in the final answer key, arguing that these errors would have awarded them an additional 21 marks, significantly impacting their results in the CGLE 2023.
Balancing Judicial Review and Expert Opinion
The Delhi High Court made an important observation regarding the scope of judicial review in examination matters. It noted that while courts should respect the expertise of subject experts, judicial review cannot be completely excluded when the correctness of answer keys is questioned.
The Court stated,
“There may be gross cases, or cases in which it is evident without any necessity for ratiocination or intricate reasoning that the answer under challenge is palpably incorrect. In such case, the interests of substantial justice have to prevail, and students who have attempted the examination cannot be allowed to suffer merely because of an obviously incorrect answer suggested by the subject experts.”
Moreover, the Court stressed the need for precision in crafting examination questions, particularly for exams with widespread implications for candidates across the country.
“Questions in examinations, which have serious and often pan-India ramifications on the candidates who undertake them, are required to be crafted both sensitively and sensibly,”
-the Court remarked.
Conclusion: Appeal Dismissed
In conclusion, the Court dismissed the SSC’s appeal, affirming the decision of the Single Judge to correct the answer key and thereby ensuring that students were not penalized for answers that were demonstrably incorrect.
This case serves as a reminder of the judiciary’s responsibility to intervene when blatant errors in examination processes lead to injustice.
CASE TITLE:
Staff Selection Commission v. Shubham Pal (Neutral Citation: 2024:DHC:7901-DB).
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