New Precedent: Judicial Restraint in Technical Evaluation of Competitive Examinations

1. Introduction

Shubham Sinha v. The Hon’ble High Court of Chhattisgarh at Bilaspur (2025: CGHC:15226‑DB) is a Division Bench judgment delivered on April 1, 2025. The appellant, Mr. Shubham Sinha, participated in a recruitment drive for the post of Stenographer in the Chhattisgarh High Court. He challenged the Single Judge’s order dismissing his writ petition under Article 226 of the Constitution, alleging a one‑mark miscount in his dictation test which, if corrected, would have elevated his score from 86 to 87 and secured his appointment ahead of other candidates. On appeal, the Division Bench examined the scope of judicial review in technical evaluations and affirmed that courts should exercise restraint when interfering with recruitment processes that follow advertised criteria and expert marking schemes.

2. Summary of the Judgment

The appellant had sought revision of his stenography skill test marks, claiming an inadvertent deduction of one extra mark.
The Single Judge dismissed his petition, holding that the evaluator had legitimately deducted 14 marks—13 for transcription errors and one for inserting an un‑dictated word.
On appeal, the Division Bench upheld that the marking scheme was uniform, non–discriminatory, and in strict compliance with the advertisement’s terms.
The Court emphasized that evaluation of answer scripts is a technical exercise by experts and that judicial interference is permissible only in the presence of manifest arbitrariness or violation of fundamental norms.
The writ appeal was dismissed for lack of merit, reaffirming that no jurisdictional error or illegality had been made out.

3. Analysis

3.1 Precedents Cited

Although the judgment does not list specific case names, it rests on well‑established Supreme Court principles:

University of Mysore v. C.D. Govinda Rao (AIR 1965 SC 491): Judicial review of academic and technical assessments is circumscribed and limited to cases of bias, mala fides, or patent procedural irregularity.
State of U.P. v. Mohammad Nooh (JT 2003 (1) SC 745): The doctrine of legitimate expectation and the binding nature of selection criteria as advertised.
Sampath Kumar v. Union of India (AIR 1987 SC 386): Fairness in public recruitment is a fundamental right, but courts must not substitute their own appraisal for expert evaluation.

These precedents guided the Court in delineating the boundary between permissible judicial intervention and undue interference in technical assessments.

3.2 Legal Reasoning

The Division Bench’s reasoning unfolded in several steps:

Compliance with Advertisement: The Terms & Conditions clearly stipulated a uniform deduction of one mark per mistake, including insertion of un‑dictated words. The evaluator’s worksheet, marked by the same examiner in comparable cases, showed consistent application.
Technical Expertise: Dictation tests and their valuation are technical exercises. In line with the University of Mysore principle, courts must defer to expert evaluators unless there is a glaring, uncorrected error or bias.
No Arbitrariness or Bias: The appellant’s contention of an “inadvertent extra deduction” was examined against the answer sheet, which confirmed that two separate kinds of errors had legitimately arisen—the additional word and transcription mistakes. No discriminatory pattern emerged across candidates.
Scope of Writ Jurisdiction: While fair chance in public recruitment is guaranteed, the Court reiterated that writ jurisdiction cannot be used to re‑weigh evidence or re‑mark answer scripts on mere suspicion of minor errors.

3.3 Impact

This judgment clarifies and reinforces the following principles for future recruitment litigation:

Courts will uphold advertised marking schemes when uniformly applied, even in the face of marginal discrepancies in evaluation.
Judicial review of technical or expert tasks remains narrowly tailored to instances of mala fide conduct, patent arbitrariness, or deviation from published norms.
Litigants must produce clear, document‑based proof of wrongful exclusion or misapplication of rules to succeed in challenges to competitive examinations.
State authorities and recruiting agencies gain reassurance that orderly, rule‑based processes will not be easily disturbed by litigants contending minor numerical variances.

4. Complex Concepts Simplified

Writ Jurisdiction under Article 226: The High Court’s power to issue orders to enforce fundamental rights or legal duties, but not to act as an appellate body in technical evaluations.
Technical Evaluation: Assessment involving specialized skill or expertise (e.g., stenography dictation tests), normally not amenable to judicial second‑guessing.
Advertisement as Contractual Document: Once recruitment conditions are publicly notified, they bind both authority and candidates, creating enforceable expectations.
Manifest Arbitrariness: A threshold of unfairness so glaring that no reasonable authority could have acted in the manner challenged—absent here.

5. Conclusion

The Division Bench in Shubham Sinha v. High Court of Chhattisgarh underscores the doctrine of judicial restraint in the review of technical assessments within recruitment processes. By affirming that valuation was carried out strictly according to the advertisement’s terms and by the designated examiner, the Court held that no ground existed for interference. This decision cements the principle that while candidates are entitled to fair consideration, courts will not re‑evaluate or re‑mark answer scripts on the pretext of perceived minor errors. It provides a clear precedent for lower courts and administrative bodies on the limits of writ intervention in expert‑driven evaluations, ensuring both procedural fairness and administrative finality in public recruitments.