Introduction

The Supreme Court of India, in the landmark case Rachna And Others v. Union Of India And Another (2021 INSC 116), addressed the contentious issue of granting additional attempts for candidates who were adversely affected by the COVID-19 pandemic during the Civil Services (Preliminary) Examination of 2020. The petitioners sought mandamus under Article 32 of the Constitution, arguing that unprecedented disruptions warranted an extension beyond the existing rules set by the Union Public Service Commission (UPSC).

The primary parties involved were the petitioner-interveners, aspirants of the UPSC Civil Services Examination who failed in their last permissible attempt due to the pandemic, and the respondents, including the Union of India and the Union Public Service Commission.

Summary of the Judgment

The Supreme Court deliberated on the petition seeking to mandate the UPSC to provide an additional attempt for candidates barred from future examinations due to either exhausting their permissible attempts or reaching the upper age limit after appearing in the COVID-19 affected 2020 examination. The court, after thorough examination, denied the petition, reinforcing the strict adherence to the established examination rules and highlighting the absence of any discretionary authority to deviate from them.

The court acknowledged the unprecedented challenges posed by the pandemic but emphasized the importance of maintaining the integrity and uniformity of competitive examinations. Consequently, the petition was dismissed, and the decision to grant a one-time restricted relaxation for specific candidates was deemed insufficient and discriminatory.

Analysis

Precedents Cited

The judgment referred to the case of Union of India v. M. Selvakumar (2017) 3 SCC 504, wherein the Supreme Court delineated the boundaries within which judicial review of policy decisions can be exercised. It emphasized that policy decisions should not be interfered with unless they are "absolutely capricious," "totally arbitrary," or lack a rational basis.

Additionally, the court referenced its earlier decision in Vasireddy Govardhana Sai Prakash v. UPSC (2021) 5 SCC 659, where it had expressed optimism about the possibility of providing one more attempt to candidates affected by the pandemic, highlighting the need for flexible policy responses in extraordinary circumstances.

Legal Reasoning

The Supreme Court's reasoning was anchored in the principle of separation of powers, asserting that policy decisions, especially those concerning examination rules, fall within the executive domain and are not subject to judicial micromanagement. The court stressed that any relaxation in rules without a statutory basis could undermine the meritocratic framework of competitive examinations.

Moreover, the court delineated the specific provisions of the Civil Services Examination Rules, 2020, particularly Rules 4 and 6, which enumerate the eligibility criteria concerning attempts and age limits. It underscored that these rules were comprehensive and did not vest any discretionary power in the UPSC to alter them post hoc, even in the face of unprecedented crises like the COVID-19 pandemic.

The court also considered the statistical data presented, revealing that less than 1.25% of candidates were directly impacted by the constraints in question. This quantitative assessment likely influenced the court's decision to uphold the existing rules without modification.

Impact

This judgment reinforces the sanctity of established examination protocols, emphasizing that exceptions to rules must be backed by clear statutory authority. For future scenarios involving disruptions, this decision signals that the UPSC must operate within the framework of its established rules unless legislative changes are enacted.

Additionally, by denying the petition, the court has set a precedent that may deter similar litigations where candidates seek discretionary relaxations based on extraordinary circumstances. Institutions conducting competitive examinations may reference this judgment to defend the rigidity of their selection criteria.

Complex Concepts Simplified

Mandamus

Mandamus is an extraordinary court order compelling a public authority to perform a duty that is legally obligated but has been neglected. In this case, the petitioners sought a writ of mandamus to obligate the UPSC to grant additional examination attempts beyond the prescribed limits.

Articles 14, 19, 21, and 29 of the Constitution of India

• Article 14: Ensures equality before the law and equal protection of the laws within the territory of India.
• Article 19: Guarantees certain freedoms to citizens, including the right to practice any profession.
• Article 21: Protects the right to life and personal liberty.
• Article 29: Protects the interests of minorities by ensuring their right to conserve their language, script, and culture.

The petitioners argued that denying them additional attempts violated these constitutional rights by discriminating against them and impeding their right to fair opportunity.

Conclusion

The Supreme Court's decision in Rachna And Others v. Union Of India And Another (2021 INSC 116) underscores the judiciary's stance on maintaining the integrity of established examination frameworks. While acknowledging the exceptional challenges posed by the COVID-19 pandemic, the court reaffirmed that procedural and substantive adherence to examination rules is paramount. This judgment serves as a definitive reference point for both candidates and regulatory bodies, delineating the boundaries of flexibility within competitive examinations and reinforcing the principles of meritocracy and uniformity in public service recruitment processes.