Supreme Court Disallows Re-evaluation of Answer Scripts in Absence of Rules: Dr. NTR University of Health Sciences vs. Dr. Yerra Trinadh (2022)

Date of the Judgment: November 4, 2022
Citation: (2022) INSC 1173
Judges: M.R. Shah, J. and M.M. Sundresh, J.
Can a High Court order the re-evaluation of answer scripts when the relevant rules do not provide for it? The Supreme Court of India addressed this critical question in a recent case concerning post-graduate diploma examinations. The Court held that in the absence of a specific provision for re-evaluation, the High Court cannot direct such re-evaluation, emphasizing the importance of adhering to established rules and regulations. The judgment was delivered by a two-judge bench comprising Justice M.R. Shah and Justice M.M. Sundresh.

Case Background

The case originated from writ petitions filed by students who were dissatisfied with the digital evaluation of their answer scripts in a post-graduate diploma course at Dr. NTR University of Health Sciences. Initially, a single judge of the High Court had issued directions on how to evaluate the answer scripts. However, the students were not satisfied with the subsequent evaluation, leading them to seek re-evaluation. The single judge, upon reviewing the records, found that the evaluation was not in line with the earlier directions and ordered a re-evaluation by four new examiners. The University challenged this decision before a Division Bench, arguing that there was no provision for re-evaluation. The Division Bench upheld the single judge’s order, leading the University to appeal to the Supreme Court.

Timeline

Course of Proceedings

The original writ petitioners, dissatisfied with the digital evaluation of their answer scripts, sought re-evaluation from the High Court. The single judge, after examining the records, concluded that the evaluation was not properly conducted and ordered a re-evaluation by four new examiners. The University appealed this decision to the Division Bench, arguing that no provision existed for re-evaluation. The Division Bench upheld the single judge’s order. The University then appealed to the Supreme Court, which, while not disturbing the results of the re-evaluation already conducted, considered the legal question of whether a re-evaluation could be ordered in the absence of a specific rule.

Legal Framework

The core legal issue revolves around the power of the High Court under Article 226 of the Constitution of India to order a re-evaluation of answer scripts when no such provision exists in the relevant rules. The Supreme Court examined this issue in light of previous judgments, particularly those emphasizing that courts should not interfere in academic matters unless there is a clear violation of rules.

Arguments

University’s Arguments:

• The University argued that in the absence of any provision for re-evaluation in the relevant rules, the High Court was not justified in ordering a re-evaluation of the answer scripts.
• They cited the Supreme Court’s decisions in Pramod Kumar Srivastava v. Chairman, Bihar Public Service Commission, Patna & Others, (2004) 6 SCC 714 and Vikesh Kumar Gupta & Another v. State of Rajasthan & Others, (2021) 2 SCC 309, which held that re-evaluation cannot be ordered if no rule provides for it.
• The University detailed the digital evaluation process, stating that it had been improved and approved by the High Court in a recent decision.

Original Writ Petitioners’ Arguments:

• The original writ petitioners contended that since they had been declared pass after re-evaluation or in supplementary exams, and had been awarded degrees, their results should not be disturbed, as per the Supreme Court’s interim order.

Issues Framed by the Supreme Court

The Supreme Court framed the following issue for consideration:

1. “Whether in the absence of any provision for re-evaluation, the High Court was justified in ordering re-evaluation after calling for the record of the answer scripts?”

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Judgment

How each authority was viewed by the Court?
The Court relied heavily on Pramod Kumar Srivastava [CITATION: (2004) 6 SCC 714], which established that re-evaluation cannot be claimed as a right in the absence of rules. The Court also cited Ran Vijay Singh [CITATION: (2018) 2 SCC 357] to highlight the need for courts to avoid interfering in academic matters and Vikesh Kumar Gupta [CITATION: (2021) 2 SCC 309] to underscore that courts lack the expertise to evaluate answer sheets.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the principle that courts should not interfere in academic matters, especially in the absence of a clear legal basis. The Court emphasized the importance of adhering to established rules and regulations, and it cautioned against the practice of High Courts calling for answer scripts to determine the need for re-evaluation. The Court also took into account the fact that the University had implemented a digital evaluation system, which had been improved and approved by the High Court.

The Court’s reasoning was based on the principle that when the rules do not permit re-evaluation, the High Court cannot order it. The Court rejected the argument that the High Court could call for the records of the answer scripts to determine whether re-evaluation was necessary, stating that this practice was impermissible. The Court also noted that the University had implemented a digital evaluation system, which had been improved and approved by the High Court, indicating that the evaluation process was robust.

The Court quoted from previous cases, emphasizing that sympathy or compassion should not play a role in directing or not directing re-evaluation of an answer sheet. The Court also highlighted that academic matters are best left to academics, and courts should not interfere in the absence of a clear violation of rules.

The Court stated, “In the absence of any provision for re-evaluation of answer-books in the relevant rules, no candidate in an examination has got any right whatsoever to claim or ask for re-evaluation of his marks.”

The Court also noted, “It is rather unfortunate that despite several decisions of this Court… there is interference by the courts in the result of examinations.”

Further, the Court observed, “the court should not re-evaluate or scrutinise the answer sheets of a candidate as it has no expertise in the matter and the academic matters are best left to academics.”

There were no dissenting opinions in this case.

Key Takeaways

• High Courts cannot order re-evaluation of answer scripts if there is no provision for it in the relevant rules.
• Courts should exercise restraint in interfering with academic matters and the decisions of examination authorities.
• Sympathy or compassion should not be a factor in deciding whether to order re-evaluation.
• The judgment reinforces the importance of adhering to established rules and regulations in the evaluation process.

Directions

The Supreme Court quashed the High Court’s order for re-evaluation but clarified that the results of the original writ petitioners who had passed after re-evaluation or supplementary exams would not be disturbed.

Development of Law

The ratio decidendi of this case is that in the absence of a specific provision for re-evaluation in the relevant rules, the High Court cannot order re-evaluation of answer scripts. This judgment reinforces the existing legal position and reiterates the principle of judicial restraint in academic matters.

Conclusion

The Supreme Court’s judgment in Dr. NTR University of Health Sciences vs. Dr. Yerra Trinadh clarifies that High Courts cannot order re-evaluation of answer scripts when the relevant rules do not provide for it. The Court emphasized the importance of adhering to established rules and regulations, and it cautioned against judicial overreach in academic matters. While the Court did not disturb the results of the re-evaluation already conducted, the judgment sets a clear precedent against ordering re-evaluation in the absence of a specific rule.

LEGAL ISSUE: Re-evaluation of answer scripts in the absence of rules
CASE TYPE: Education Law, Examination Law
Case Name: Dr. NTR University of Health Sciences vs. Dr. Yerra Trinadh & Others
Judgment Date: November 4, 2022