Reaffirmation of Principles Governing Judicial Review of Examination Answer Keys and CLAT-2025 Objection Procedure

Introduction

In SHIVRAJ SHARMA v. CONSORTIUM OF NATIONAL LAW UNIVERSITIES & ORS. (2025 DHC 2838), a Division Bench of the Delhi High Court (Chief Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela) addressed multiple writ petitions and Letters Patent Appeals arising out of challenges to the final answer key of the Common Law Admission Test (CLAT-2025). The Consortium had published provisional answer keys and invited objections within a narrow window. After finalizing its key, dozens of candidates approached various High Courts—including this Court—seeking corrections, deletions and revaluation. At issue were the proper scope of judicial review over answer keys, the admissibility of belated challenges, the standard for overturning expert-prepared keys, and remedies for manifest errors or out-of-syllabus questions.

Summary of the Judgment

After examining over 16 sample questions from four paper-sets (A, B, C, D), the Court reaffirmed that:

Writ courts may intervene in answer‐key disputes only in “rare and exceptional cases” when an answer is “palpably and demonstrably wrong” without intricate reasoning.
Candidates who do not object within the published window are precluded from belated challenges under Article 226; such tardy petitions are dismissed to preserve finality.
Where questions are out of the announced syllabus or contain drafting errors (e.g., wrong cross‐references), they must be treated as withdrawn and full marks awarded to all who attempted them.
On manifest numerical or typographical mistakes attributed to the Consortium—such as mis-numbering between Question 115 and 116 in Sets B, C & D—marks must be granted to all affected candidates.

Consequently, the Court upheld the final answer key in the vast majority of instances, set aside one question as “out of syllabus” (Q. 77), directed deletion of another where data was inadequate (Q. 88), and ordered blanket relief for questions 115 & 116. The Consortium was directed to re-publish the merit list within four weeks.

Analysis

Precedents Cited

Ran Vijay Singh v. State of U.P. (2018) 2 SCC 357
Established that courts may re‐evaluate answer keys only in rare, exceptional instances of clear error; general deference must be shown to academic and expert bodies.
Staff Selection Commission v. Shubham Pal (2024 SCC OnLine Del 7144)
Reiterated that while the judicial “hands‐off” approach applies to subject‐expert determinations, courts cannot abdicate their duty where the error is glaring and injustice results.
Salil Maheshwari v. High Court of Delhi (2014 SCC OnLine Del 4563)
Held that a candidate who fails to object within the stipulated window is estopped from belatedly challenging the final key after results are out.

Legal Reasoning

The Court applied the following guiding principles:

Presumption of Correctness: Final answer keys issued by the Consortium are presumed correct unless a challenge demonstrates a clear, self-evident error.
Limited Review: Judicial scrutiny of academic expert decisions must remain confined to detecting patent mistakes, not substituting judicial views on subject‐matter intricacies.
Finality and Procedure: Procedural deadlines for objections—publicized in the admission notification—must be strictly enforced to avert perpetual litigation and ensure confidence in the examination process.
Equitable Relief for Drafting Errors: Where the Consortium itself mis‐prints or mis‐references questions across different sets, the Court will direct that full marks be awarded to all affected candidates.
Out-of-Syllabus Doctrine: Questions that fall outside the notified syllabus or unlawfully demand prior legal knowledge (contrary to “Legal Reasoning” rules) are struck down and treated as withdrawn.

Impact

This judgment carries significant implications for educational and administrative law:

It cements the “rare and exceptional cases” standard for judicial interference in exam answer‐key disputes, discouraging frivolous litigation.
It underscores the binding nature of objection windows, preventing candidates from gaming the system via belated writ petitions.
It provides a roadmap for exam authorities to manage and document their provisional/final key processes transparently, including expert and oversight committee deliberations.
It amplifies candidate protection where drafting errors occur, promoting fairness by granting blanket relief rather than forced re‐examinations.
It clarifies the out-of-syllabus principle, ensuring that competitive exams adhere to notified curricula and rules on permissible subject knowledge.

Complex Concepts Simplified

Provisional vs. Final Answer Key: The provisional key is a draft published immediately after an exam, inviting objections. The final key incorporates accepted corrections.
Expert Committee & Oversight Committee: Two layers of subject‐matter review within the Consortium. Objections go first to experts, then to an oversight panel if needed.
Article 226 Writ Jurisdiction: High Courts can issue writs to enforce fundamental rights or correct administrative excess—but must respect procedural bars and deference norms.
Manifest Error Standard: Courts will intervene only when a key answer is so obviously wrong that no reasonable expert body could endorse it.
Out-of-Syllabus Question: Any question outside the announced syllabus or exam rules is invalid; affected candidates get full marks without retake.

Conclusion

The Delhi High Court’s 2025 decision in SHIVRAJ SHARMA v. CONSORTIUM OF NATIONAL LAW UNIVERSITIES & ORS. reaffirms judicial restraint in reviewing academic determinations, enforces strict adherence to procedural deadlines, and ensures equitable relief for drafting errors. By upholding most of the Consortium’s final answer key while carving out exceptions for out‐of‐syllabus questions and mis‐numbered sets, the Court struck a balanced course—protecting exam integrity without sacrificing candidate fairness. This precedent will guide future challenges to competitive‐exam answer keys across India.