Isabella Mariam

The High Court of Delhi Division Bench of Justice C Hari Shankar and Justice Om Prakash Shukla dismissed a petition by a Delhi Judicial Services Examination, 2023 candidate seeking restoration of marks and a revision of the examination’s final result, after alleging that her Paper I marks were altered and reduced at the last stage of evaluation. The Court declined to order any restoration or re-evaluation, holding that, absent pleaded or established mala fides, subjective assessment and mark changes made during evaluation are not amenable to judicial substitution. It noted that interference at this stage could open floodgates, trigger cascading consequences, and make the selection process unworkable, and that courts should accord due latitude to examining authorities in academic evaluation.

The writ petition arose from the Delhi Judicial Services Examination, 2023. The petitioner, who appeared in the Mains examination, alleged that twenty marks awarded to her in Paper-I were subsequently reduced after initial evaluation. As reflected on page 4 of the judgment, the marks for Question Nos. 5 and 8 were altered from 25 to 15 and from 30 to 20 respectively, and the total on the front page of the answer script was changed from 191 to 171 and then corrected to 169.

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The petitioner contended that the reduction was arbitrary and unsupported by any statutory provision. She argued that once marks were recorded in figures and words, the examiner had no authority to revise them. Reliance was placed on precedents permitting interference in cases of interpolation.

The respondents submitted that evaluation of subjective answers fell within the examiner’s domain, that the changes were made prior to submission of answer scripts, and that re-evaluation was barred under the Delhi Judicial Services Rules, 1970. They further contended that no mala fide or bias had been pleaded and that appointments had already been made pursuant to the selection process.

The Court recorded that the petitioner’s grievance related to alleged arbitrary reduction of marks and that the central issue was whether such alteration warranted interference under Article 226. It observed, “At the outset, we find merit in the submission of Respondent No. 1 that the expression ‘interpolation’ carries an imputation of mala fide.” The Court noted that the petitioner had neither pleaded nor established mala fide or bias.

Referring to settled law on academic matters, the Court stated, “It is a settled principle of law that courts must exercise restraint in academic matters and refrain from substituting their own assessment for that of expert examiners.” It further recorded that the answers in Question Nos. 5 and 8 were subjective in nature and that there existed no objective standard by which the Court could determine correctness of marks.

On the prohibition against re-evaluation, the Court reproduced the relevant rule: “There shall be no re-evaluation of answer sheets in respect of Preliminary Examination and Mains Examination (Written). No request for re-evaluation of answer sheets shall be entertained and the same shall be liable to be rejected without any notice to the candidates.”

The Court also referred to Supreme Court precedent and recorded: “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.”

Addressing the timing of revisions, the Court stated, “since the revisions in the present case were made while the answer scripts remained within the exclusive domain of the examiner, i.e., before communicating the results to Respondent No. 1, the same are legally permissible.”

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It further recorded, “We find that the marks initially awarded to individual answers and reflected in the aggregate were subsequently changed, does not, by itself, establish arbitrariness or illegality, particularly where such revisions were made prior to finalization of results and in the absence of any allegation of mala fide or bias. The petitioner's assertion that the reduction was effected only to lower her aggregate remains conjectural and unsupported by material evidence,”

In considering the effect on selected candidates, the Court noted “Any direction for re-evaluation would necessarily require extending such exercise to all similarly placed candidates to maintain parity, thereby disturbing concluded selections and disrupting inter se seniority. Such uncertainty in public appointments is antithetical to the principles of fairness, administrative stability and predictability. Judicial interference in such circumstances would open floodgates, leading to cascading consequences and rendering the process unworkable.”

The Courtheld, “Consequently, this Court finds no justification to restore the alleged original marks or to direct re-evaluation of the impugned answers, having due regard to the autonomy of the examiner and the settled limits of judicial review. As a sequel to the aforesaid, the present writ petition as being without any merits, is dismissed accordingly. Pending applications, if any, stand disposed of.”

Case Title: Prerna Gupta v. Registrar General of Delhi High Court & Ors.
Neutral Citation: 2026: DHC:983-DB
Case Number: W.P.(C) 10517/2025
Bench: Justice C. Hari Shankar and Justice Om Prakash Shukla