The “Dual-Key & Deletion Doctrine” – Supreme Court’s New Framework for Judicial Review of Entrance-Examination Questions
Commentary on Siddhi Sandeep Ladda v. Consortium of NLUs & Anr. (2025 INSC 714, decided 07 May 2025)

1. Introduction

The Common Law Admission Test (CLAT) is the gateway to India’s National Law Universities (NLUs). In the 2025 session, several aspirants alleged that multiple questions were either factually incorrect, ambiguous or outside the stated syllabus. Ms. Siddhi Sandeep Ladda, alongside numerous similarly situated candidates, challenged the final answer key before the Delhi High Court. Dissatisfied with the partial relief granted there, she appealed to the Supreme Court.

The appeals required the Court to decide whether it should interfere in the academic domain yet again, and if so, to what extent. The judgment delivered by Justices B. R. Gavai and Augustine George Masih refines the principles governing judicial review of entrance examinations and devises a pragmatic mechanism—the Dual-Key & Deletion Doctrine—for handling erroneous multiple-choice questions.

2. Summary of the Judgment

• Questions 56, 77, 78, 88, 115 and 116 of CLAT-UG 2025 were scrutinised.
• Question 56: Two options (“c” and “d”) were held correct. Positive marks directed for both; negatives only for “a” or “b”.
• Question 77: Held a valid in-syllabus question; correct answer “b” (voidable agreement). Candidates choosing “b” entitled to marks; others get negative.
• Question 78: High Court view sustained; answer “c” (agreement to pay ₹10 lakh for a government job) stands.
• Question 88: Deleted, parity reasoned from comparable deletion of Question 85.
• Questions 115 & 116: Both deleted owing to excessive mathematical complexity and cross-referencing errors.
• Consortium ordered to issue a revised key, re-publish ranks, and begin counselling within two weeks.
• Court expressed “deep anguish” at CLAT’s recurrent deficiencies and hinted at reviving scrutiny in the pending Public Interest Litigation filed by late Prof. Shamnad Basheer.

3. Analysis

3.1 Precedents Cited & Their Influence

1. Disha Panchal v. Union of India (2018) 17 SCC 278 – The Court then had constituted a Committee for CLAT reforms, criticising inconsistent conduct by rotating host universities. The present Bench invoked this precedent to show that persisting irregularities legitimise continued judicial oversight.
2. Shamnad Basheer v. Union Of India (WP(C) 600/2015) – Though pending, this PIL serves as an umbrella under which structural reforms may be directed; the Court flagged the need to place the committee report therein.
3. General academic-review jurisprudence (Ran Vijay Singh v. State of U.P., (2018) 2 SCC 357; Kanpur University v. Samir Gupta, (1983) 4 SCC 309) – While reiterating reluctance to interfere in academic matters, the Bench carved out an exception where “academicians themselves act in a manner that adversely affects the career aspirations of lakhs of students”.

3.2 Legal Reasoning

(a) Standard of Scrutiny

The Court acknowledged its traditional self-restraint in educational matters but emphasised that arbitrariness, manifest error, or violation of fairness principles invites judicial correction. The Bench located this power under Articles 14 and 21, connecting entrance-exam integrity to candidates’ right to fair opportunity in professional education.

(b) Adoption of “Dual-Key” Approach

For Question 56, two options were logically tenable. Rather than pick one, the Court awarded marks for both. This marks a shift from the older practice of deleting such questions altogether, preserving merit ranking where possible.

(c) The “Deletion” Principle

When ambiguities were incurable (Questions 88, 115, 116), deletion was ordered, ensuring uniform total marks for all candidates. The deletion remedy is conditioned on incapacity to locate a single or multiple unequivocally correct options.

(d) Logical-Reasoning Test

For Question 77, the Court held that a candidate could answer using only the passage supplied; hence prior legal knowledge was unnecessary. This underscores that the CLAT’s “comprehension-based” model is court-validated, provided the passage actually enables deduction.

(e) Equality of Treatment

By deleting question 116 across all paper sets (and not just where cross-referencing errors appeared), the Bench insisted on horizontal parity among examinees, foreclosing any advantage or prejudice arising from paper-set variance.

3.3 Potential Impact

• Examination design: Paper-setters must now contemplate that ambiguous questions may result in either dual-key marking or deletion, both of which affect scoring curves. Incentivises rigorous vetting before publication.
• Legal education governance: Pressure will mount on the Consortium to professionalise question-setting, perhaps outsource psychometric validation, and centralise duties rather than annual rotation among NLUs.
• Broader entrance tests: NEET, JEE, UPSC and State PSCs may cite this precedent when faced with answer-key challenges; the dual-key solution offers a middle path between deletion and absolutism.
• Judicial workload: By articulating clearer remedial typologies, the judgment could streamline future litigation; High Courts can apply the doctrine without needing Supreme Court intervention each time.

4. Complex Concepts Simplified

• Void vs. Voidable Agreement
  • Void – Invalid from the outset (void ab initio); cannot be enforced by any party.
  • Voidable – Valid unless the “aggrieved” party repudiates it (e.g., contracts with minors, or formed under coercion).
  • In Q 77, the presence of a minor made the contract voidable at that minor’s option.
• Fundamental Duty to Preserve Environment
  Articles 48-A & 51-A(g) impose duties on both State and citizens to protect the environment.
• Dual-Key
  A remedy where multiple options are deemed correct; all selecting those options earn marks; negatives apply to the rest.
• Deletion of Question
  A problematic question is struck off; marks are scaled to a reduced total so nobody gains an unfair edge.
• Cross-Referencing Error
  When a question erroneously instructs candidates to rely on information in another (incorrect or absent) question, rendering it unsolvable.

5. Conclusion

The Supreme Court’s decision in Siddhi Sandeep Ladda crystallises a pragmatic, candidate-centric framework for adjudicating disputes over competitive-examination questions. By blending restraint with targeted intervention, the Court:

• Reaffirmed the principle that fairness in high-stakes testing is integral to equality and life opportunities.
• Introduced the Dual-Key & Deletion Doctrine—a calibrated toolkit that balances correction of examiner error with preservation of ranking integrity.
• Placed the onus squarely on the Consortium of NLUs to professionalise and standardise CLAT conduct.
• Signalled willingness to revisit systemic reforms through the pending Shamnad Basheer PIL, potentially reshaping governance of legal-education admissions.

In the broader legal context, the judgment serves both as a caution to examining bodies and as guidance to courts handling similar challenges: judicial review in academic matters is exceptional, yet unavoidable where institutional lapse threatens the legitimate expectations of aspirants nationwide.