Prerna Gupta's Petition Challenging Mark Reduction in Delhi Judicial Services Examination Dismissed
In a significant ruling, the Delhi High Court dismissed a petition filed by Prerna Gupta, challenging the reduction of her marks in the Delhi Judicial Services Examination (DJSE) 2023. The division bench, comprising Justices C. Hari Shankar and Om Prakash Shukla, upheld the examination authority's discretion in the evaluative process, emphasizing the limitations on judicial review concerning academic assessments.
Prerna Gupta, an unsuccessful candidate in the DJSE, alleged that her marks in Paper-I of the Mains examination were unlawfully reduced, impacting her final ranking. She sought the restoration of the original marks, arguing that the reduction was arbitrary and lacked procedural justification. Gupta contended that the examiner's revision of marks was an afterthought, not supported by any legitimate rationale or transparency.
The court, however, found no merit in Gupta's claims, stating that the reduction of marks did not imply mala fide intent, bias, or fraud on the part of the examiners. The judges underscored the importance of academic judgment in the evaluation of subjective answers, asserting that courts should refrain from substituting their own opinions for that of the experts.
The Delhi Judicial Services Rules, 1970, which govern the examination process, expressly prohibit re-evaluation of answer sheets, limiting judicial intervention to instances of demonstrable material error or manifest arbitrariness. The court noted that Gupta failed to establish any such error or arbitrariness to warrant judicial interference.
Furthermore, the court emphasized that any changes in marks were made before the submission of answer scripts to the examining authority, thereby falling within the legitimate scope of the examiner's discretion. The bench highlighted the potential disruption to public appointments and inter se seniority if judicial interference were to occur, as 51 out of 53 selected candidates had already joined service.
The court also invoked the doctrine of estoppel, pointing out that Gupta, having participated in the selection process with full knowledge of the applicable rules, could not challenge the procedure or outcome upon being declared unsuccessful.
Ultimately, the court dismissed the petition, affirming the autonomy of the examiner and the settled limits of judicial review in academic matters. The ruling reinforces the principle that courts should exercise restraint in interfering with examination processes, ensuring administrative stability and predictability in public appointments.
Bottom Line:
Judicial review in examination matters is limited and does not extend to reassessment of subjective marks unless there is demonstrable material error or allegations of mala fide, bias, or fraud.
Statutory provision(s): Article 226 of the Constitution of India, Delhi Judicial Services Rules, 1970 Rule 15
Prerna Gupta v. Registrar General of Delhi High Court, (Delhi)(DB) : Law Finder Doc id # 2850038
