Supreme Court Upholds Rajasthan Civil Judge Exam Results: Sonal Gupta vs. Registrar General (2024)

Date of the Judgment: 24 October 2024

Citation: 2024 INSC 830

Judges: Dr Dhananjaya Y Chandrachud, CJI, J B Pardiwala, J, Manoj Misra, J.

Can the Supreme Court intervene when candidates receive unexpectedly low marks in a subjective exam? This question was at the heart of a recent case where candidates for the Rajasthan Civil Judge cadre challenged their results, alleging arbitrary marking in the English Essay paper. The Supreme Court of India, in this judgment, addressed the issue of whether discrepancies in marking warranted the quashing of results and re-evaluation of answer sheets. The judgment was delivered by a three-judge bench comprising of Dr. Dhananjaya Y Chandrachud, CJI, J B Pardiwala, J, and Manoj Misra, J.

Case Background

The petitioners, a group of 109 candidates, had appeared for the main examination of the Rajasthan Civil Judge Cadre 2024. This examination is a crucial step in the recruitment process for Civil Judges in Rajasthan, as per the Rajasthan Judicial Services Rules 2010. The selection process involves three stages: a preliminary examination, a main examination, and an interview round. The main examination includes four papers: Law Paper-I (Civil), Law Paper-II (Criminal), Language Paper-I (Hindi Essay), and Language Paper-II (English Essay). The petitioners had cleared the preliminary examination held on 23 June 2024. The main examination took place on 31 August 2024 and 1 September 2024. The results were declared on 1 October 2024. The petitioners were aggrieved by the low marks they received in the Language Paper-II (English Essay), which led to them not qualifying for the interview round. They sought the quashing of the results and re-evaluation of their answer sheets by an expert committee.

Timeline

Course of Proceedings

A petition was filed in the High Court of Rajasthan under Article 226 of the Constitution on identical issues, which was dismissed on 19 October 2024, in light of the proceedings commenced before the Supreme Court. The Supreme Court took cognizance of the matter and issued notice on 18 October 2024, directing the production of answer sheets of candidates who scored below fifteen marks in the English essay. The Court further directed a tabulated statement of marks of candidates who scored between zero and fifteen in the English Essay, who have not qualified for the interview stage to be placed before the court.

Legal Framework

The recruitment process for Civil Judges in Rajasthan is governed by the Rajasthan Judicial Services Rules 2010. Rule 16 of the RJS Rules stipulates that recruitment shall be made directly on the basis of a competitive examination. Rule 20 outlines the three-stage selection process: preliminary examination, main examination, and interview round. Schedule IV of the RJS Rules details the scheme of the written examination. The minimum cut-off marks for qualifying for the viva voce in law papers are 35% for the unreserved category and 30% for Scheduled Caste and Scheduled Tribe categories. Candidates must have an aggregate of 40% (35% for SC/ST candidates) to be eligible for the interview. No minimum marks are stipulated for language papers.

Arguments

The Petitioners argued that there were serious discrepancies in the marks awarded for the English Essay examination. Their submissions are as follows:

• Skewed Marking: In the absence of minimum qualifying marks for the language papers, the marking was skewed. Candidates who qualified in the law papers were awarded unreasonably low marks in the English essay paper.

• Inexplicable Zero Marks: Candidates who attempted the paper were awarded zero marks. Since the paper is subjective, the award of no marks is inexplicable.

• Limited Space: The limited space in the Question Paper-cum-Answer Booklet hindered the ability of candidates to answer appropriately.

• Time Constraint: Over fourteen thousand answer sheets were checked by a limited number of examiners within a span of one month between the date of examination and the declaration of results.

The petitioners contended that the marking system was arbitrary and unfair, leading to deserving candidates being excluded from the interview stage.

Issues Framed by the Supreme Court

The core issue before the Supreme Court was:

1. Whether there is any arbitrary variation in the marks obtained by candidates in the language examination which may affect the integrity of the overall results of the examination.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Judgment

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

How each authority was viewed by the Court?

✓ The Court relied on Sanjay Singh v. UP Public Services Commission, (2007) 3 SCC 720* to acknowledge that a degree of variation may occur when a large number of candidates are evaluated through an examination by a number of evaluators, however, the likelihood of discrepancy arises when a wide variation can be made out from the results.

✓ The Court followed Pranav Verma v. High Court of P&H, (2020) 15 SCC 377* to observe that the likelihood of discrepancy is reduced where the evaluation process is uniform. The Court also noted that evaluation done by multiple evaluators i.e. one evaluator examining and marking one question in all the marksheets, ensures uniformity and prevents chance grading.

✓ The Court cited Prashant Ramesh Chakkarwar v. UPSC, (2013) 12 SCC 489* to hold that in the absence of any evidence that meritorious candidates have been deprived of their marks deliberately, the Court cannot interfere. Merely because candidates who cleared the preliminary exam did not further clear the main exam is no ground to infer fault on part of the examining authority.

✓ The Court also noted that the present petitions failed to qualify the parameters followed by the Court in a consistent line of precedent as laid down in Sujasha Mukherji v. High Court of Calcutta, (2015) 11 SCC 395*, CPIL v. High Court of Delhi, (2017) 11 SCC 456*, and Pavan Verma v. High Court of P&H, (2020) 15 SCC 377*.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• Uniform Evaluation Process: The Court emphasized that the evaluation process was uniform, with different examiners assessing different questions. This reduced the likelihood of arbitrary marking.

• Lack of Evidence of Deliberate Low Marking: The Court found no evidence to suggest that the examiners deliberately awarded low marks in the English Essay paper. The perusal of answer sheets did not reveal any deliberate attempt to lower scores.

• Statistical Analysis: The Court found no statistical discrepancy that would warrant intervention under Article 32 of the Constitution. The fact that a large number of candidates received low marks did not, in itself, indicate an infirmity in the assessment process.

• Precedents: The Court relied on previous judgments to conclude that the marking of the essay did not suffer from an infirmity that would cast doubt on the overall assessment of the English Essay answer sheets.

Sentiment Analysis of Reasons Given by the Supreme Court

Fact:Law Ratio

The Court’s reasoning was a mix of factual analysis and legal principles, with a greater emphasis on the factual aspects of the case.

Logical Reasoning

The Court’s reasoning followed a logical progression from examining the evaluation process to reviewing evidence and applying precedents.

Key Takeaways

The key takeaways from this judgment are:

• Uniform Evaluation is Crucial: The judgment emphasizes the importance of having a uniform evaluation process, where different examiners assess different questions to ensure fairness and reduce discrepancies.

• Judicial Intervention is Limited: The Supreme Court will not intervene in the absence of concrete evidence of deliberate low marking or significant statistical discrepancies. Merely receiving low marks is not sufficient grounds for judicial intervention.

• Burden of Proof: The burden of proof lies with the petitioners to demonstrate that there was a deliberate attempt to lower scores. General allegations of unfairness are insufficient.

• Importance of Precedents: The Court relied on a consistent line of precedents to decide the matter.

Directions

The Supreme Court dismissed the petitions. However, it granted liberty to any candidate with an individual grievance, save and except for the issue concluded by this order, to move the High Court of Rajasthan under Article 226 of the Constitution.

Development of Law

The ratio decidendi of this case is that the Supreme Court will not interfere with the evaluation process of a competitive examination unless there is concrete evidence of deliberate low marking or significant statistical discrepancies. This judgment reinforces the principle that the Court’s role is limited in matters of academic evaluation, and that the burden of proof lies with the petitioners to demonstrate any infirmity in the process.

Conclusion

In conclusion, the Supreme Court dismissed the petitions challenging the results of the Rajasthan Civil Judge Cadre 2024 main examination. The Court found no evidence of arbitrary marking in the English Essay paper and upheld the integrity of the evaluation process. The judgment underscores the importance of uniform evaluation processes and the limited scope for judicial intervention in academic matters. The Court also granted liberty to any candidate with an individual grievance to move the High Court of Rajasthan.