The Supreme Court has reiterated that a power of judicial review cannot be exercised to interfere with the decision of experts in an academic field.

A bench of Justice Dipankar Datta and Justice Sheel Nagu set aside the Allahabad High Court's order, which had interfered with the academic experts' decision in examination matters.

The High Court issued directions to the Uttar Pradesh Public Service Commission regarding the re-evaluation of answer scripts, the deletion of certain questions, and the awarding of full marks for others.

Calling them to be in clear violation of the law laid down in Ran Vijay Singh v. State of Uttar Pradesh (2018) 2 SCC 357, the Court observed:

“…the High Court in our considered view exceeded the jurisdiction of a judicial review court in its interference with the decision of experts in the academic field. The manner of examination of the so-called dubious questions pertaining to different topics by the High Court, as if it were an expert of experts, and in making the directions it did are clearly indefensible.”

In Ran Vijay Singh (supra), the Court laid down the principles on judicial interference in examination matters:

"1. If a statute, Rule or Regulation governing an examination permits the re-evaluation of an answer sheet or scrutiny of an answer sheet as a matter of right, then the authority conducting the examination may permit it;

2. If a statute, Rule or Regulation governing an examination does not permit re-evaluation or scrutiny of an answer sheet (as distinct from prohibiting it) then the court may permit re-evaluation or scrutiny only if it is demonstrated very clearly, without any “inferential process of reasoning or by a process of rationalisation” and only in rare or exceptional cases that a material error has been committed;

3. The court should not at all re-evaluate or scrutinise the answer sheets of a candidate—it has no expertise in the matter and academic matters are best left to academics;

4. The court should presume the correctness of the key answers and proceed on that assumption; and

5. In the event of a doubt, the benefit should go to the examination authority rather than to the candidate."

The Court observed that the High Court undertook an elaborate examination of disputed questions from different academic disciplines and effectively substituted its own assessment for that of subject experts.

The Court underscored that judicial review in such matters is intended to examine the legality of the decision-making process and not to reassess academic determinations.

The appeal was accordingly allowed.

Cause Title: U.P. PUBLIC SERVICE COMMISSION THROUGH ITS CHAIRMAN & ANR. VERSUS SUNIL KUMAR SINGH & ORS.

Citation : 2026 LiveLaw (SC) 784

Click here to download Order

Appearance:

For Appellant(s) : Mr. Siddharth, AOR Ms. Himanshi Girdhar, Adv. Mr. Deepanshu Grover, Adv.

For Respondent(s) :Mr. Satyajeet Kumar, AOR (N/P) Mr. Rajnish Kumar Jha, AOR (N/P) Mr. Satyajeet Kumar, AOR (N/P)

Related: Supreme Court Disapproves High Courts' Practice Of Calling For Answer Scripts For Ordering Revaluation

[Public Service Recruitment] Judicial Review Should Be Rarely Exercised If Provision For Revaluation Of Answer Sheets Is Absent: SC