Judicial Intervention in Objective Exam Answer-Keys: Power to Correct Demonstrably Wrong Keys

Introduction

AKANKSHA PRIYA v. STATE OF JHARKHAND (2025 JHHC 12325-DB) is a landmark decision of the Jharkhand High Court delivered on April 25, 2025. A Constitution Bench of Chief Justice M.S. Ramachandra Rao and Justice Deepak Roshan heard a batch of writ petitions filed by candidates who had appeared for the Civil Judges (Junior Division) Preliminary Examination conducted by the Jharkhand Public Service Commission (JPSC). The petitioners challenged the Commission’s revised answer-keys for certain objective questions—arguing that the new keys were demonstrably wrong. The State and the JPSC resisted, submitting that the Rules contain no provision for re-evaluation of answer-sheets and that courts should not meddle in academic matters.

Key issues:

Whether a writ court can correct or direct correction of an objective test answer-key when no statutory or regulatory right of re-evaluation exists.
Whether the petitioners successfully demonstrated that three specific questions (Nos. 8, 74 and 96 in Booklet A) were wrongly keyed.

Summary of the Judgment

The Court held that even in the absence of any rule permitting re-evaluation or scrutiny of answer sheets, Article 226 empowers it, in rare and exceptional cases, to correct an answer-key that is “demonstrably wrong” without depending on inferential reasoning or rationalization. Applying settled Supreme Court precedents, the High Court examined the three challenged questions and found:

Question 8 (English grammar): Option A (“More than one boy was absent…”) was correct; the Commission’s revised Option B was wrong.
Question 74 (Criminal law, IPC sections): The Supreme Court’s Ashwini Kumar Upadhyay judgment mentioned Sections 153A, 153B, 295A and 505 IPC—not Section 506—so the Commission’s Option D was wrong.
Question 96 (Agency under Indian Contract Act): Both Options B and C were incorrect statements of law; the Commission’s final Option A was wrong.

The Court directed the JPSC to:

Delete Questions 74 and 96 from scoring;
Award one mark each to candidates who answered Option A for Question 8;
Recalculate each candidate’s aggregate on a 100-mark scale (post-deletion of two questions) and apply category-wise cut-offs;
Publish a revised merit list within four weeks.

Analysis

Precedents Cited

Kanpur University & Ors. v. Samir Gupta & Ors. (1983 4 SCC 309): Exam keys should stand unless “clearly demonstrated” to be wrong by recognized authorities in the subject; mere inferential reasoning is inadequate.
Himachal Pradesh PSC v. Mukesh Thakur (2010 6 SCC 759): No right of re-evaluation in absence of statutory/regulatory provision; courts may not direct re-evaluation of answer sheets.
Ran Vijay Singh & Ors. v. State of U.P. & Ors. (2018 2 SCC 357): Courts may interfere in rare/exceptional situations to correct answer keys if error is demonstrated “without any inferential process of reasoning” and “no reasonable body of men well-versed” would accept the key.
High Court of Tripura through RG v. Tirtha Sarathi Mukherjee & Ors. (2019 16 SCC 663): Even absent re-valuation rules, writ courts can intervene where a correct answer is marked wrong “beyond the slightest doubt.”
Other supporting authorities: U.P. PSC v. Rahul Singh (2018 7 SCC 254), Manish Ujwal v. Maharishi Dayanand Saraswati University (2005 13 SCC 744).

Legal Reasoning

The Court applied a two-step analysis drawn from Supreme Court authority:

Presume correctness of the Commission’s key answers and undertake a strict review: error must be “clearly demonstrated” without inference or rationalization.
Intervene only in “rare and exceptional” cases, mindful that courts lack technical or academic expertise in setting objective tests.

Finding that the petitioners had placed before the Court unambiguous statutory or authoritative textual support—text-book usage, the IPC text, and Indian Contract Act provisions—the Court concluded that no reasonable expert could uphold the Commission’s revised keys to the three questions. The absence of a re-evaluation rule did not bar judicial correction of the key itself.

Impact

This decision establishes a robust precedent in Jharkhand (and persuasive elsewhere) that:

Writ courts may correct an objective exam’s answer-key in rare, demonstrable cases of error, even where no regulation provides for re-evaluation.
Candidates bear a heavy burden: they must prove that the key is “palpably wrong” on its face and beyond the realm of reasonable dispute.
Such intervention is narrow—limited to correcting the key, not re-evaluating entire answer sheets or substituting judicial expertise for academic experts.

Going forward, examining authorities will be under heightened pressure to ensure flawless keys, especially in legal and language subjects. Candidates may be encouraged to challenge keys directly in writ forums, but only with compelling textual or authoritative support.

Complex Concepts Simplified

Inferential Process of Reasoning: Drawing conclusions by interpretation rather than by plain, uncontested textual authority. Courts will not overturn keys on such grounds.
Demonstrably Wrong: An answer is demonstrably wrong if no reasonable expert, consulting authoritative texts or statutes, could regard it as correct.
Re-evaluation vs. Key Correction: Re-evaluation means re-marking a candidate’s answer sheet; key correction means amending which answer choice is treated as correct. The Judgment allows the latter in narrow cases.
Cut-off Re-scaling: When questions are deleted post-exam, marks are recalculated proportionally to preserve the 100-mark scale before applying pass thresholds.

Conclusion

AKANKSHA PRIYA v. STATE OF JHARKHAND crystallizes the principle that high courts, under Article 226, have the power to correct objective test answer keys in rare and exceptional cases—even where no rule for re-evaluation exists—provided the key’s error is demonstrated beyond reasonable doubt and without inferential reasoning. This decision balances judicial restraint in academic matters with candidates’ right not to be penalized by an obviously incorrect key. It reinforces rigorous standards for answer-key preparation and offers a precise pathway for fair redress when an authoritative text or statute unequivocally contradicts a published key.