Expressing serious concerns over the declining standards of legal education in the Law Colleges, the Allahabad High Court recently directed that a redacted copy of a law student's evaluated answer book, in which he was awarded zero marks, along with the question paper, be sent to the Bar Council of India (BCI) and the Law Commission of India.

The Court asked the BCI to consider whether the standards of legal education presently maintained and the existing mechanism for approval, affiliation and periodic inspection of law institutions require strengthening "to compete with globally competitive legal education standards".

Similarly, the bench also urged the Law Commission to examine the broader issue of legal education standards and consider reforms, if deemed appropriate.

A bench of Justice Vinod Diwakar passed these directions while dismissing a writ petition filed by a B.A. LL.B. student. The petitioner had sought re-evaluation of his answer book in the "Bio-Diversity Protection Law" paper of the IX Semester Examination, 2025-26.

Case in brief

It was the case of the petitioner-student that, despite attempting all the questions and expecting to secure more than 50 marks, he had been awarded zero marks throughout the paper.

He obtained a copy of the evaluated answer book under the Right to Information Act and sought re-evaluation after the University allegedly took no action on his representations.

High Court's order

During the hearing, the Court called for the original answer book and question paper. It also directed the Standing Counsel to read one of the answers written by the petitioner in open court.

After examining the answer, the Court found that it did not reveal any legal understanding of the subject.

In its order, the Court noted that the Standing Counsel admitted that he "unable to comprehend the purport of the answer or discern any coherent reasoning, factual narration or legal proposition relatable either to the question asked or to the subject of 'Bio-Diversity Protection Law".

Examining the answer book himself, Justice Diwakar also agreed that it was incomprehensible. He remarked thus:

"The answer to Question No. 3-C does not disclose any legal understanding of the subject. Consequently, no fault can be found with the evaluation undertaken by the examiner in awarding zero marks for the said answer. Similar is the position with the remaining answers contained in the answer book".

Reiterating the settled principles on judicial review in academic matters, the Court observed that interference with evaluation is permissible only where arbitrariness, mala fides, violation of statutory provisions, or a patent error in the evaluation process is established.

On examining the original records of the case, the Court found no material that suggested that the petitioner had suffered prejudice or that the examiner had acted arbitrarily in awarding zero marks. Accordingly, the writ petition was dismissed.

While declining relief to the petitioner, the Court, however, remarked that the case reflected a larger systemic concern.

Justice Diwakar observed that the petitioner-Student was pursuing a professional degree intended to prepare students for entry into the legal profession, but the quality of his answers gave rise to "serious concern" regarding the academic standards maintained at the institution where he was receiving the legal education.

Stressing that legal education constitutes the foundation of the justice delivery system, the bench remarked thus:

"Legal education constitutes the foundation of the justice delivery system. Any substantial decline in academic standards at the institutional level affects not merely the legal profession, but the administration of justice itself".

The Court added that this was not a solitary instance and that matters of this nature had come before the Court with disquieting frequency.

The Court also observed that the deficiency could not be attributed entirely to the student. It added that had the student been "properly counselled" before the examination, provided a suitable orientation programme and adequately taught, supervised and apprised of what was expected of an examinee, such answers would not have been written.

It remarked that the deficiency, if any, lay "as much in the institution's failure to discharge its responsibility of imparting quality education as in the answers produced by the student".

Against this backdrop, the Court requested the Bar Council of India to examine whether the institution concerned continued to satisfy the prescribed academic and infrastructural standards.

It observed that the BCI would be free to undertake such inspection or inquiry as it deemed appropriate in accordance with law after affording the institution an opportunity of hearing.

The Court specifically requested the BCI to consider "whether the standards of legal education presently maintained are commensurate with the object for which they are prescribed, and whether the existing mechanism for the grant of approval of affiliation to, and the periodic inspection of, institutions imparting legal education requires strengthening to compete with globally competitive legal education standards".

The Court also stated that the Law Commission of India may examine the issue for the formulation of such proposals for reform in legal education as the Commission may deem appropriate.

It clarified that its observations were intended only to invite the attention of these bodies to a matter of general concern and should not be construed as findings against the institution, its teachers, or the examiner, none of whom were parties before the Court.

Accordingly, the Registrar (Compliance) was directed to forward to the Principal Secretary of the Bar Council of India a copy of the judgment, along with redacted copies of the question paper and the student's answer book, for such consideration as the BCI may deem fit.

Case title - XXX vs. State of U.P. & 3 Ors. 2026 LiveLaw (AB) 545

Case Citation: 2026 LiveLaw (AB) 545

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