“Rules of the Game Cannot Be Changed”: Madras HC Dismisses Plea by Disabled Candidate Over TNPSC Exam Sheet Rejection for Missing Signature
Sanchayita Lahkar
The Madras High Court has dismissed a writ petition challenging the rejection of an answer sheet submitted in the Tamil Nadu Public Service Commission’s (TNPSC) Combined Civil Services Examination-IV (Group-IV) due to the petitioner’s failure to affix a signature or thumb impression as mandated by the examination instructions. A Single Bench of Justice C.V. Karthikeyan, observed that the instructions issued by the TNPSC are mandatory, and non-compliance would render the answer sheet unfit for valuation.
The Court stated that “the instructions issued by the Commission are mandatory and the Court, in exercise of powers under Article 226 of the Constitution of India, cannot modify or relax these conditions.” The petitioner’s omission to affix a signature or thumb impression resulted in the non-evaluation of his answer sheet, in line with TNPSC guidelines.
The petitioner, a person certified as a locomotor disabled individual with a disability percentage of 62% by the Regional Medical Board, Chennai, had appeared for the TNPSC Group-IV services examination conducted on 09.06.2024. The examination was held pursuant to Advertisement No.1/2024 dated 30.01.2024, under which the petitioner applied under the differently abled persons category. The petitioner had previously sustained multiple injuries, including restricted movement of his right hand and left leg, impairment of his left eye, and speech difficulties.
Due to his physical condition, a scribe and a separate room were allotted for the petitioner’s use during the examination. The petitioner completed answering the questions within the permitted time, following which the scribe submitted the answer sheet to the invigilator. However, the petitioner did not affix his signature in the relevant column. The instructions issued by the TNPSC required candidates to either affix their signature or, in the event of inability, a left or right thumb impression depending on the candidate's condition. The petitioner did not affix either thumb impression.
The TNPSC subsequently marked the answer sheet as invalid for valuation, citing non-compliance with the instructions. The petitioner sought a writ of certiorarified mandamus to quash the decision of the TNPSC and direct the respondents to evaluate his answer sheet, declare his marks, and permit him to proceed with certificate verification for appointment to a suitable post under the Group-IV recruitment process.
In support of his petition, the petitioner submitted that despite his disability, he had completed the examination and that the omission to affix a signature or thumb impression should not have disqualified his answer sheet from evaluation. The petitioner’s counsel argued that the sheet could be identified through the registration number and a lenient approach could be adopted to permit evaluation.
In response, TNPSC submitted that the instructions provided to all candidates, including those availing the scribe facility, clearly stipulated the requirement for affixing a signature or thumb impression. The Commission contended that no exemption under clause 4.10 of the instructions applied to the petitioner, as he had not shown that both hands were disabled. The respondents maintained that the omission was in direct contravention of the examination instructions, rendering the answer sheet invalid.
The Court considered the petitioner’s submission and the counter affidavit filed by TNPSC. Justice Karthikeyan recorded the applicable instructions as follows:
- Candidates with benchmark disability must affix their signature and left hand thumb impression in the space provided in the answer sheets, if possible.”
- Visually disabled/orthopaedically disables candidates who have been permitted to use scribe facility, who are unable to affix their signature, may affix their left hand thumb impression alone in the space provided in Part I of the OMR answer sheet after the closure of examination.”
- Candidates who are unable to use their left hand, must affix right hand thumb impression.”
- Candidates who are unable to use both hands, and who have been permitted to use scribe, may leave the signature and thumb impression columns blank.”
- OMR answer sheet is not signed by the candidate at all required places.”
The Court noted that the petitioner, in his affidavit, had stated that he had suffered injuries and paralysis in his right hand but had not mentioned that both hands were paralyzed, which would have exempted him under clause 4.10. The Court recorded, “he has not specifically stated that both his hands had suffered paralysis and that he could not sign at all.”
On the petitioner’s argument for a lenient approach to permit identification through registration number, the Court noted that accepting such a plea would exceed the prescribed procedure. Justice Karthikeyan recorded, “the submissions made by the learned counsel across the bar is appreciated, but acceding to the same would be far exceeding the scope of examination and changing the rules of the game.”
The Court found that the TNPSC’s requirement for affixing the signature or thumb impression was unequivocal and could not be modified or bypassed in an individual case. It further noted that permitting deviation would open the floodgates for other candidates to seek similar relaxations.
Justice Karthikeyan referenced the Supreme Court’s decision in Ran Vijay Singh and Others v. State of Uttar Pradesh and Others [(2018) 2 SCC 357], which stated, “sympathy or compassion does not play any role in the matter of directing or not directing re-evaluation of an answer sheet.” The Court also quoted from the judgment: “If an error is committed by the examination authority, the complete body of candidates suffers. The entire examination process does not deserve to be derailed only because some candidates are disappointed or dissatisfied or perceive some injustice having been caused to them by an erroneous question or an erroneous answer.”
Justice Karthikeyan also noted the Supreme Court’s remarks on the necessity of upholding the integrity of examination systems: “this unsatisfactory situation does not work to anybody's advantage and such a state of uncertainty results in confusion being worse confounded. The overall and larger impact of all this is that public interest suffers.”
Additionally, the Court referred to Civil Appeal No.6669 of 2019 (arising out of SLP No.14093 of 2019), wherein the Supreme Court held that “the instructions issued by the Commission are mandatory, having the force of law and they have to be strictly complied with.” The Court reiterated that “the High Court in exercise of powers under Article 226 of the Constitution cannot modify/relax the instructions issued by the Commission.”
The Court also recorded submissions regarding reliance on a prior decision in C. Priyadarshini v. TNPSC and Another, where a learned Single Judge had granted relief on grounds of partial compliance with signature requirements. However, it was noted that “the said observation of the learned Single Judge had been stayed by the Division Bench in C.M.P.No.5773 of 2024 in W.A.No.833 of 2024 vide order dated 13.03.2024.”
The respondents further cited the order in S. Priya v. The Secretary, TNPSC, Chennai (W.P.No.6558 of 2024), where a writ petition was dismissed for violation of the same instructions.
The Court found that there was no merit in the petitioner's plea and recorded, “the writ petition has to fail only owing to the petitioner not having affixed his signature in the answer sheet.” Accordingly, the Court dismissed the writ petition without costs and closed the connected miscellaneous petitions.
Advocates Representing the Parties
For the Petitioner : Mr. R. Sivakumar
For the Respondent : Ms. G. Hema, Standing Counsel
Case Title: A. Mohamed Ibrahim versus The Secretary, The Tamil Nadu Public Service Commission and Another
Neutral Citation: 2025:MHC:657
Case Number: W.P.No.33691 of 2024
Bench: Justice C.V. Karthikeyan
[Read/Download order]
