Kiran Raj

The Madras High Court, in a judgment delivered on March 10, 2025, by Justice C.V. Karthikeyan, dismissed a writ petition challenging the evaluation of the Tamil Eligibility Test conducted for recruitment to the post of Assistant Surgeon (General). The case revolved around the petitioner's claim that her examination results were unfairly assessed, leading to her disqualification from the recruitment process. The court upheld the expert committee's evaluation and stated that judicial interference in academic matters should be limited.

The petitioner, Dr. A.G. Rajasri, had applied for the post of Assistant Surgeon (General) under Notification No.01/MRB/2024 issued by the Medical Services Recruitment Board (MRB). The recruitment process involved two stages: a Tamil Eligibility Test of 50 marks with a minimum qualifying score of 20 marks (40%) and a subsequent computer-based test evaluated only if the candidate cleared the Tamil test. The Tamil Eligibility Test was conducted on January 5, 2025.

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The petitioner secured only 18 marks in the test, which was below the required minimum qualifying mark of 20. She challenged the correctness of the evaluation, arguing that questions 10, 25, and 35 were incorrectly assessed. She contended that her answers were correct and, if appropriately evaluated, would increase her total score to 21, thereby making her eligible for the next stage of the recruitment process.

The petitioner's counsel, Senior Advocate Mrs. Nalini Chidambaram, presented that question 10 was incorrectly answered by the petitioner but insisted that questions 25 and 35 contained ambiguities and errors that should have led to a revision of her marks. Regarding question 25, she argued that two possible answers were correct, while for question 35, she pointed out a typographical error in the question itself, which, according to her, should have invalidated the question.

The respondents, represented by Additional Advocate General Mr. J. Ravindran, countered these claims by arguing that the Tamil Eligibility Test was evaluated based on expert committee recommendations and that courts should not assume the role of an academic review authority. The respondents produced reference materials and expert opinions supporting the correctness of the key answers used for evaluation.

Justice C.V. Karthikeyan considered the legal position governing judicial intervention in academic matters and the importance of deference to expert opinions in such scenarios. He cited various Supreme Court judgements that state the necessity of restricting judicial review in academic assessments unless a case of mala fide action, procedural lapses, or fundamental irregularity is established.

The court noted:

“The law on the subject is therefore, quite clear… The court should not at all re-evaluate or scrutinise the answer sheets of a candidate—it has no expertise in the matter and academic matters are best left to academics.” (Ran Vijay Singh v. State of Uttar Pradesh, 2018 SCC 357)

In reference to question 25, the petitioner argued that both options (A) and (B) should have been considered correct. However, the court upheld the respondents’ position that the correct answer was determined based on government-prescribed textbooks and expert verification. The court cited the Supreme Court judgment in Basavaiah v. Dr. H.L. Ramesh (2010 SCC 372), which established the principle that courts should respect the decisions of academic experts unless clear evidence of bias or procedural unfairness is demonstrated.

With regard to question 35, the petitioner argued that a typographical error rendered the entire question invalid and that candidates should have been awarded marks by default. The respondents countered that the expert committee had reviewed the alleged error and determined that it did not affect the substantive meaning of the question. The court held:

“Unless the Court were to impute mala fide on the part of the expert who set the question paper… the Court should not embark on a journey to question the correctness of the opinion of the expert.”

Justice Karthikeyan further cited precedent from Ran Vijay Singh v. State of Uttar Pradesh (2018 SCC 357), which held that courts should avoid interfering in examination matters unless a clear legal provision allows for re-evaluation. The court recorded:

“In the event of a doubt, the benefit should go to the examination authority rather than to the candidate.”

The court acknowledged the rigorous process undertaken by the examination authority, including the setting of questions, independent verification by subject-matter experts, and the review of answer keys before finalizing evaluation criteria. The court found no procedural lapses or bias in this process and declined to substitute its judgment for that of the academic experts.

Additionally, the court examined whether any provision in the recruitment notification allowed for re-evaluation or challenge to the key answers. Finding none, the court stated that the petitioner had no inherent right to demand a revision of her marks unless a clear error of law was established. The court stated:

“The role of the Court to re-evaluate and re-examine and re-scrutinize the correctness of the answers as projected by the respondents is extremely narrow.”

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The writ petition was dismissed, with the court stating:

“I hold that the challenge to these questions should necessarily fail as it is beyond the scope of judicial review to examine the correctness or otherwise of the key answers, even if it is to be taken that the answers as projected by the petitioners are also be probably correct.”

The final orders were:

1. The petition challenging the Tamil Eligibility Test evaluation is dismissed.

2. The expert committee’s assessment of question numbers 10, 25, and 35 is upheld.

3. The connected writ miscellaneous petition is also closed.

Advocates Representing the Parties

• For Petitioner:  Mrs. Nalini Chidambaram, Senior Advocate

• For Respondent No.1 (State of Tamil Nadu):  Mr. E. Sundaram, Government Advocate

• For Respondent No.2 (MRB):  Mr. J. Ravindran, Additional Advocate General assisted by Mr. L. Murugavel

Case Title: Dr. A.G. Rajasri v. The State of Tamil Nadu & Anr.

Case Number: W.P.No. 6491 of 2025

Bench: Justice C.V. Karthikeyan

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