Telangana High Court Upholds Digital Double-Valuation In PG Medical Exams; Says Courts Cannot Re-Assess Academic Evaluation

The Telangana High Court has upheld the validity of the digital double-valuation system used in postgraduate medical examinations, holding that courts cannot interfere with academic evaluation merely on allegations of discrepancies in marks.

A Single Judge Bench of Justice Renuka Yara observed:

“This Court lacks expertise in said arena… It is the domain of the valuators… to value the answer scripts… In any case, to avoid arbitrariness… whenever there is a difference of 15% or more, said paper is sent for valuation by a third valuator and therefore, the scope for arbitrariness is reduced.”

The Court held that the method adopted by the University of valuation being conducted by two examiners with a third evaluation in case of significant divergence provides sufficient safeguards and cannot be termed arbitrary.

The case arose from a batch of postgraduate medical students who challenged the results of examinations conducted in October 2025. The petitioners alleged serious irregularities in the evaluation process, pointing to a sharp increase in the failure rate, from 1-2% in previous years to about 11% for their batch.

They contended that although they had “attempted all the questions and submitted their answers correctly,” their answer scripts were “not valued properly in accordance with statutory regulations.” Several candidates were declared failed by margins as narrow as 1–5 marks, either in aggregate or in individual papers.

Significantly, the petitioners relied on instances of re-evaluation to demonstrate alleged arbitrariness. They pointed out that when one candidate sought revaluation, it was found that “for some of the answers she has written, no marks were assigned,” and she was subsequently declared to have passed. It was further claimed that at least 4–5 candidates were similarly declared passed after re-evaluation despite initially failing. The petitioners also referred to reports of the Vice-Chancellor's resignation following the controversy.

On this basis, it was argued that the results gave “ample scope for suspicion about the arbitrariness” of the evaluation process.

The petitioners argued that the evaluation process lacked transparency and consistency. They claimed that marks were not assigned question-wise in the answer scripts, that evaluators lacked adequate time or qualification, and that the digital valuation process reduced meaningful application of mind. It was also contended that earlier High Court decisions required evaluation by a larger panel of examiners, which had not been followed.

Opposing the petition, the University maintained that the evaluation process strictly followed the prescribed system of digital valuation. It submitted that answer scripts were scanned and independently assessed by two evaluators, with a third evaluator stepping in wherever there was a substantial difference in marking. The respondents also emphasized that there is no provision permitting re-evaluation once results are declared, which is why action was taken against the then Vice-Chancellor for violating the rules.

The Court held that the challenge was founded on a misunderstanding of the evaluation framework. It clarified that the requirement of multiple examiners relates to the conduct of examinations, whereas valuation is governed by a separate scheme that expressly provides for double evaluation with a third check in defined circumstances.

The Court further noted that variations in marks between evaluators, by themselves, do not establish arbitrariness, particularly when a structured mechanism exists to address such differences. It also refused to entertain a granular comparison of marks awarded question-wise, “as this Court lacks expertise in said arena.”

On the reliance placed on earlier judgments, the Court distinguished them by noting that they were decided under the Medical Council of India (MCI) Postgraduate Medical Education Regulations, 2000, particularly Regulation 14(1)(b), which required evaluation by multiple examiners but did not contain a specific framework governing valuation of answer scripts.

In contrast, the present case is governed by the Post-Graduate Medical Education Regulations, 2023 (PGMER-23) issued by the NMC, which introduce a distinct provision under Regulation 8.4 (Valuation). The Court emphasised that while Regulation 8.2 (Examiners) under the 2023 Regulations is analogous to Regulation 14(1)(b) of the 2000 Regulations in relation to conduct of examinations, the 2000 framework had no equivalent to Regulation 8.4 dealing specifically with valuation.

Concluding that no illegality or arbitrariness was made out, the Court held that the writ petition was “misconceived” and dismissed it.

Case Title: Durgam Venkatesh Kumar & Ors. v. State of Telangana & Ors.

Case No.: W.P. No. 471 of 2026

Appearance:

– For Petitioners: Sri Mahadev Anyarambhatla

– For State: Sri R. Nagarjuna Reddy, AGP (Medical, Health & FW)

– For University: Sri T. Sharath, Standing Counsel

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