Precedents Cited

The judgment heavily relied on several landmark decisions to delineate the boundaries of judicial intervention in examination processes:

• Ran Vijay Singh v. State of Uttar Pradesh (2018) 2 SCC 357: Emphasized that courts should refrain from re-evaluating answer sheets unless a material error is evident.
• Vikesh Kumar Gupta v. State of Rajasthan (2021) 2 SCC 309: Reinforced the principles established in Ran Vijay Singh, highlighting the limited scope of judicial review in expert opinions.
• Kanpur University v. Samit Gupta (1983) 4 SCC 309: Stressed that the correct answer key should be presumed accurate unless convincingly proven otherwise without inferential reasoning.
• Uttar Pradesh Public Service Commission v. Rahul Singh (2018) 7 SCC 254: Highlighted the burden of proof on candidates to demonstrate the patently wrong nature of key answers.
• Ramdhan Kumawat v. The State Of Rajasthan & Anr. (2014) SBCWP No. 10622/2014: Allowed re-evaluation when expert committee decisions were not aligned with standard educational materials.
• Hari Singh v. Rajasthan Public Service Commission (2009) SBCWP No. 12621/2009: Asserted that errors by the expert committee in adhering to standard texts warrant judicial intervention to ensure fairness.
• Richal v. Rajasthan Public Service Commission (2018) 8 SCC 81: Demonstrated the court's willingness to order re-evaluation based on expert committee findings when clear discrepancies exist.

Legal Reasoning

The court recognized the delicate balance between maintaining the integrity of the examination process and ensuring fairness to the candidates. It acknowledged that while expert committees are entrusted with the responsibility of evaluating answer keys, their decisions must align with prescribed educational materials. The court reiterated that judicial intervention is reserved for instances where there is an apparent and glaring error devoid of any inferential reasoning.

Applying the principles from the cited precedents, the court evaluated whether the expert committee's decisions for questions No. 132 and 144 were arbitrary or influenced by objective discrepancies with standard texts. Finding that these changes were inconsistent with the prescribed materials, the court deemed them to be beyond the permissible scope of expert discretion, thereby warranting judicial oversight.

Impact

This judgment reinforces the limited scope of judicial intervention in administrative processes, particularly in public examinations. It underscores the judiciary's stance in deferring to expert committees unless clear evidence of error is presented. By mandating re-evaluation only for questions where discrepancies with standard materials are evident, the court ensures that the examination authorities are held accountable for adhering to prescribed guidelines.

For future cases, this sets a precedent that while judicial bodies will respect the expertise of examination committees, they remain vigilant against arbitrary or unsupported alterations to answer keys. It also emphasizes the necessity for examination authorities to base their decisions strictly on approved educational materials to avoid judicial challenges.

Estoppel

Estoppel is a legal principle that prevents a party from arguing something contrary to a claim they previously made when it would harm the other party. In this case, since the petitioners did not raise objections to certain questions when initially presented, they are barred from later contesting those same questions.

Judicial Review

Judicial review refers to the power of courts to examine the actions of administrative bodies or officials to ensure they comply with the law. Here, the court limited its review to only those alterations in the answer key that were evidently incorrect without logical reasoning.

Prima Facie

"Prima facie" refers to evidence that is sufficient to establish a fact or raise a presumption unless disproven by other evidence. The petitioners provided prima facie evidence that certain answer key changes were incorrect, warranting further judicial examination.