Chhattisgarh High Court Quashes Departmental Exam Result, Says Syllabus Can't Be Changed Through Admit Cards Issued Days Before Exam
The Chhattisgarh High Court has held that introducing a new subject in a departmental examination only through admit cards issued a few days before, or even hours before, the examination cannot be treated as a valid or adequate prior notification of the syllabus. The Court further observed that if the omission of a subject from the published syllabus was due to a clerical or typographical...
The Chhattisgarh High Court has held that introducing a new subject in a departmental examination only through admit cards issued a few days before, or even hours before, the examination cannot be treated as a valid or adequate prior notification of the syllabus. The Court further observed that if the omission of a subject from the published syllabus was due to a clerical or typographical error, the authorities were required to rectify the mistake by granting the petitioners adequate notice and sufficient time to prepare for the newly introduced subject, rather than merely mentioning it in the admit cards issued immediately before the examination.
Justice Bibhu Datta Guru was hearing a batch of writ petitions filed by employees who had appeared in the Subordinate Accounts Service (Departmental) Examination, Part II, conducted between 8 August and 14 August 2017. The petitioners contended that the prescribed syllabus for Paper-V was "Company Accounts and Store Control (Graduation Level)”. However, when the examination was conducted, questions came from "Cost Accountancy", a subject outside the notified syllabus.
They further alleged that certain questions contained incorrect figures and that, despite objections being raised, the authorities rejected them by order dated 22 November 2024 without properly considering their grievances. The respondents defended the examination by contending that omission of "Cost Accountancy" from the advertisement was merely a clerical error and that the complete title of Paper V had been mentioned in the admit cards issued before the examination.
The Court observed that the published syllabus did not include Cost Accountancy and that the subject was introduced for the first time through the admit cards. It also noted that while some candidates received their admit cards only a few days before the examination, others received them at the examination centre just a few hours before the examination commenced. Hence, the petitioners had no prior notice or reasonable opportunity to prepare for the newly introduced subject of Cost Accountancy.
“If the omission of the subject from the published syllabus was on account of a typographical or clerical error on the part of the respondent authorities, it was incumbent upon them to rectify the mistake by granting the petitioners adequate notice and sufficient time to prepare for the newly introduced subject, rather than merely mentioning it in the admit cards issued immediately prior to the examination,” the Court observed.
The Court further emphasized that the rules of the game cannot be changed after the game has begun. It held that if the authorities intended to alter or correct the syllabus, they were required to do so by issuing a proper corrigendum or a fresh notification sufficiently in advance of the examination so as to afford the candidates a reasonable opportunity to prepare.
“In the absence of such a valid re-notification, the respondents could not alter the basis of selection at the eleventh hour through the admit cards. Such a course is contrary to the settled doctrine that the rules of the game cannot be changed after the game has commenced,” the Court observed.
Accordingly, the Court allowed the writ petitions and quashed the orders rejecting the petitioners' objections and the examination result.
Case Title: C.L. Sandilya v. State of Chhattisgarh & Ors. and connected matters [WPS No. 2904 of 2025 and connected petitions]