“Courts Cannot Substitute Expertise of Selection Committees”: Madras High Court Refuses to Intervene in Dispute Over Medical Recruitment Answer Key
Sanchayita Lahkar
The Madras High Court has declined to interfere with the provisional selection list for the post of Assistant Surgeon (General) issued by the Medical Services Recruitment Board, holding that courts cannot override the decisions of expert bodies in academic or technical matters. The Single Bench of Justice C.V. Karthikeyan recorded that “the Court cannot substitute itself for an expert to determine whether the key answer as given by the respondents are correct or whether the key answer as given by the petitioner alone is correct.” The Court observed that the judiciary must respect institutional expertise and procedural fairness. The petition was dismissed without granting relief.
The petitioner, a medical graduate, had applied for the post of Assistant Surgeon (General) pursuant to Notification No.01/MRB/2024 dated 15.03.2024 issued by the Medical Services Recruitment Board (second respondent). He appeared for the recruitment examination held on 05.01.2025. The provisional answer keys were released on 08.01.2025. Upon evaluation, the petitioner obtained 58 marks. He claimed he was entitled to 61 marks and challenged the correctness of key answers to Question No.5 and Question No.20.
The key answer to Question No.5 was marked as option 'a' by the Board, while the petitioner contended that option 'b' was the only correct answer, relying on Davidson’s Principles and Practice of Medicine, 24th Edition. For Question No.20, where the key answer was 'd', the petitioner asserted that 'b' was correct, relying on Harrison’s Manual of Medicine, 20th Edition and Ganong’s Review of Medical Physiology, 26th Edition. The petitioner did not file any independent representation raising objections during the initial answer key challenge process.
The prayer in the writ petition sought a writ of certiorarified mandamus to quash the provisional selection list (PSL No.01/MRB/2024 dated 20.02.2025) and to direct the formation of an Expert Committee to reassess the correctness of answers to the disputed questions. The petitioner also sought consequential directions to revise the selection list and to include him among the selected candidates.
The learned counsel for the petitioner referred to several judgments to support the plea that courts may intervene where manifest errors are demonstrated. These included Kanpur University v. Samir Gupta [(1983) 4 SCC 309], where the Supreme Court observed that “the key answer should be assumed to be correct unless it is proved to be wrong... it must be such as no reasonable body of men well-versed in the particular subject would regard as correct.” Specific reliance was placed on paragraphs 16, 17 and 20 of the decision.
Further references were made to Harvinder Singh Johal v. Registrar General, Punjab and Haryana High Court [2019 SCC OnLine P&H 3912] and Rishal v. Rajasthan Public Service Commission [(2018) 8 SCC 81], wherein the Apex Court acknowledged the process of inviting objections as part of ensuring transparency and fairness in competitive exams.
In response, the Additional Advocate General submitted that the MRB had disclosed the source materials and that the answer keys were prepared by subject matter experts. He argued that judicial review over expert academic determinations was impermissible unless mala fides or patent illegality were shown. Reliance was placed on Uttar Pradesh Public Service Commission v. Rahul Singh [(2018) 7 SCC 254], where the Supreme Court held that “Judges cannot take on the role of experts in academic matters” and that courts must “presume the correctness of key answers and proceed on that assumption.”
Extensive reference was also made to the decision in Ran Vijay Singh v. State of Uttar Pradesh [(2018) 2 SCC 357], where the Supreme Court outlined that “if an error is committed by the examination authority, the complete body of candidates suffers... mathematical precision is not always possible.”
Justice C.V. Karthikeyan examined the judgments cited and recorded the scope of judicial review in such cases. The Court observed that “the scope of this Court to convert itself as an expert over and above an Expert Committee had been examined by the Hon’ble Supreme Court”. The judgment referred to Basavaiah v. Dr. H.L. Ramesh [(2010) 8 SCC 372], stating that “the High Court ought not to have sat as an appellate court on the recommendations made by the country’s leading experts.”
The Court recorded that “the petitioner only claims that the answers as projected by him alone are correct” and “the learned counsel had only advanced arguments projecting the reference materials as instructed by the petitioner.” The Court noted that the petitioner had not alleged mala fides and had not submitted any objection during the official process.
Referring to The University of Mysore v. C.D. Govinda Rao [AIR 1965 SC 491], the Court observed that “normally the Courts should be slow to interfere with the opinions expressed by the experts, particularly in a case when there is no allegation of mala fides.”
Citing M.C. Gupta v. Arun Kumar Gupta [(1979) 2 SCC 339], it was stated that “courts should be slow to interfere with the opinion expressed by experts unless there are allegations of mala fides.” Further reference was made to J.P. Kulshrestha v. Allahabad University [(1980) 3 SCC 418], where the Court reiterated that “courts should hesitate to dislodge decisions of academic bodies.”
The Court referred to the Constitution Bench decision in Maharashtra State Board v. Paritosh Bhupeshkumar Sheth [(1984) 4 SCC 27], where it was held that “courts should be extremely reluctant to substitute their own views in preference to those formulated by professional men possessing technical expertise.”
Reviewing these authorities, Justice Karthikeyan stated that “the precedents very clearly and categorically stated that the High Court cannot substitute itself for an expert and when there is no mala fide alleged against the Committee constituted by Experts, their opinion must be upheld.”
The judgment additionally quoted from Pramod Kumar Srivastava v. Bihar Public Service Commission [(2004) 6 SCC 714], where the Supreme Court held that in the absence of a rule permitting re-evaluation, courts should not direct it. The Madras High Court concluded that “it would normally be prudent, wholesome and safe for the courts to leave the decisions to the academicians and experts.”
The Court declined to grant the relief sought in the writ petition and held that judicial review was not permissible in the absence of any illegality or mala fide. It recorded that, “this Court cannot substitute itself for an expert to determine whether the key answer as given by the respondents are correct or whether the key answer as given by the petitioner alone is correct.” The judgment further stated, “no mala fide has been alleged against the Expert Committee” and that “their opinion must be upheld and no other opinion should be examined or stated by the Court.”
The Court also stated, “it would normally be prudent, wholesome and safe for the Courts to leave the decisions to the academicians and experts.” The final directive in the judgment reads: “this Writ Petition stands dismissed. No costs.”
Advocates Representing the Parties
For the Petitioner: Mrs. Y. Kavitha for P.V.S. Giridhar Associate
For the Respondents: Mr. M. Bindran, Additional Government Advocate; Mr. J. Ravindran, Additional Advocate General assisted by Mr. L. Murugavelu; Mr. U. Bharanidharan
Case Title: Dr. Akash. S v. The State of Tamil Nadu and Others
Case Number: W.P.No.7711 of 2025 and W.M.P.Nos. 8655 & 8657 of 2025
Bench: Justice C.V. Karthikeyan
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