Supreme Court Modifies High Court Order on CLAT 2025: Siddhi Sandeep Ladda vs. Consortium of National Law Universities (2025)

Introduction

Date of the Judgment: May 07, 2025

Citation: 2025 INSC 714

Judges: B.R. Gavai, J. and Augustine George Masih, J.

Did errors in the Common Law Admission Test (CLAT) 2025 adversely affect the career aspirations of thousands of students? The Supreme Court of India recently addressed this critical question in an appeal against a High Court order concerning the CLAT 2025 examination. The core issue revolved around the accuracy and suitability of several questions in the CLAT 2025 question paper. Justices B.R. Gavai and Augustine George Masih, constituting the bench, delivered the judgment, modifying the High Court’s order to ensure fairness for all candidates.

Case Background

The case originated from a batch of writ petitions filed across various High Courts, challenging the conduct of CLAT. These petitions were later transferred to the High Court of Delhi. The Division Bench of the High Court addressed these petitions, leading to the appeals before the Supreme Court. The primary concern was the framing of questions for CLAT 2025 by the Consortium of National Law Universities, which the Supreme Court found to beCallous and casual.

Timeline

Legal Framework

The judgment references several legal provisions and principles:

• Article 48A of the Constitution of India: This article, introduced by the 42nd Constitutional Amendment Act of 1976, explicitly includes the concept of environmental protection.
• Article 51A(g) of the Constitution of India: This article also relates to environmental protection, imposing a fundamental duty on citizens to protect and improve the natural environment.
• Article 21 of the Constitution of India: Guarantees the right to life and personal liberty, which the Supreme Court has interpreted to include the right to a clean environment.
• Section 2(h) of the Contract Act 1872: Defines a contract as an agreement enforceable by law.

Arguments

Arguments on behalf of the Appellants:

• The questions framed for CLAT 2025 were flawed and ambiguous.
• The answer keys provided by the Consortium of National Law Universities (Respondent No. 1) were incorrect.
• The High Court’s decision needed modification to ensure fairness to all candidates.

Arguments on behalf of the Respondents:

• The questions were designed to test the logical reasoning and comprehension skills of the candidates.
• The answer keys were prepared by experts and were generally accurate.
• The High Court’s order was justified and should be upheld.

Specific Arguments Related to Question No. 56:

• Respondent No. 1 argued that the correct answer to Question No. 56 was option (d), stating that the State has the duty to maintain ecological balance and citizens have the right against climate change.
• Respondent No. 1 contended that the use of the word “citizens” in answer option (c) (Both the state and citizens have the duty to preserve natural resources) was inappropriate because the material provided used the phrase “State and its residents.”

Specific Arguments Related to Question No. 77:

• Respondent No. 1 argued that even without prior legal knowledge, a candidate could have answered Question No. 77 correctly by applying logic and reason to the material provided.
• Respondent No. 2 and intervenors contended that answering Question No. 77 required prior knowledge of law, specifically the Indian Contract Act, 1872.

Specific Arguments Related to Question No. 78:

• Respondent No. 2 argued that the most appropriate answer to Question No. 78 was not option (c).
• Respondent No. 1 contended that answer option (c) was the correct answer.

Specific Arguments Related to Question No. 88:

• Respondent No. 1 argued before the High Court that the answer to Question No. 88 should be option (d) (Data inadequate).

Submissions Table

Issues Framed by the Supreme Court

1. The primary issue before the Supreme Court was to examine the correctness and suitability of specific questions in the CLAT 2025 examination.
2. Sub-issues included whether the High Court’s directions regarding Questions No. 56, 77, 78, 88, 115, and 116 were justified and whether modifications were necessary to ensure fairness to all candidates.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The court considered the following authorities:

Cases Relied Upon:

• Disha Panchal and Others v. Union of India through the Secretary and Others, (2018) 17 SCC 278 : 2018 INSC 553 – This case highlighted improper conduct in previous CLAT examinations and led to the formation of a committee to address shortcomings.

Legal Provisions Considered:

• Article 48A of the Constitution of India – Introduced the concept of environmental protection.
• Article 51A(g) of the Constitution of India – Imposes a fundamental duty on citizens to protect the environment.
• Article 21 of the Constitution of India – Guarantees the right to life, including the right to a clean environment.
• Section 2(h) of the Contract Act 1872 – Defines a contract.

Authority Treatment Table

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• Disha Panchal and Others v. Union of India through the Secretary and Others, (2018) 17 SCC 278 : 2018 INSC 553: The Court referred to this case to emphasize the need for remedial measures and penal action against the body entrusted with conducting the examination, highlighting the previous concerns regarding the conduct of CLAT.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the need to ensure fairness and maintain the integrity of the CLAT examination process. The Court emphasized that academic bodies must act responsibly to avoid adversely affecting the career aspirations of students. The key factors that weighed in the mind of the Court include:

• The ambiguity and flaws in the questions framed for CLAT 2025.
• The incorrect answer keys provided by the Consortium of National Law Universities.
• The need to provide equal footing to all candidates.

Sentiment Analysis Ranking of Reasons Given by the Supreme Court:

Fact:Law Ratio Analysis:

Logical Reasoning

Question No. 56:

Material provided states both State and residents have a duty → Respondent argues “residents” ≠ “citizens” → Court finds argument unconvincing → Court directs positive marks for options (c) and (d)

Question No. 77:

Material defines voidable contracts → High Court deems prior legal knowledge necessary → Court finds logic and reason sufficient → Court directs positive marks for option (b)

Question No. 88:

Question similar to deleted Question No. 85 → Respondent provided answer option (d) → Court finds inconsistency → Court directs deletion of Question No. 88

Question No. 115:

Question requires detailed mathematical analysis → Objective test should not require such analysis → Court directs deletion of Question No. 115

Question No. 116:

Question based on information in Question No. 115 → Question No. 115 deleted → To ensure equal footing, Question No. 116 must also be deleted → Court directs deletion of Question No. 116

Key Takeaways

• Academic bodies must ensure the accuracy and suitability of questions in competitive examinations.
• Fairness and equal opportunity are paramount in the examination process.
• Courts may intervene in academic matters when necessary to protect the interests of students.
• The Consortium of National Law Universities was directed to amend the answer key, revise the marksheet, and re-publish the final list of candidates.

Directions

The Supreme Court directed the Consortium of National Law Universities to:

• Amend the answer key.
• Revise the marksheet.
• Re-publish/notify the final list of candidates forthwith.
• Commence with the counselling within 2 weeks from the date of the judgment.

Development of Law

The ratio decidendi of the case is that academic bodies have a responsibility to ensure the fairness and accuracy of competitive examinations, and courts can intervene when these bodies fail to do so. This judgment reinforces the importance of maintaining the integrity of the examination process and protecting the career aspirations of students.

Conclusion

The Supreme Court’s judgment in Siddhi Sandeep Ladda vs. Consortium of National Law Universities (2025) underscores the critical need for academic bodies to conduct competitive examinations with utmost diligence and fairness. By modifying the High Court’s order and directing specific actions to rectify the errors in CLAT 2025, the Supreme Court reaffirmed its commitment to protecting the interests of students and upholding the integrity of the examination process.