Saravanan M v. The Principal Secretary To Government
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 18.03.2025
CORAM:
THE HONOURABLE MR.JUSTICE R.SURESH KUMAR and THE HONOURABLE DR.JUSTICE A.D.MARIA CLETE and C.M.P. No. 1198 of 2023 Mr. Saravanan M, S/o. E. Mohan, 42, Annai Theresa Street, ESI, Anna nagar, Annanur, Chennai - 600 109.
... Appellant Vs.
1.The Principal Secretary to Government, Home Department, Fort St.George, Chennai - 600 009.
2.The Director General of Police/Chairperson, Tamil Nadu Uniform Services Recruitment Board, Anna Salai, Chennai - 600 002.
3.Member Secretary, Tamil Nadu Uniformed Service Recruitment Board, Old Commissioner of Police Campus, 1/9
Pantheon Road, Egmore, Chennai - 600 008.
... Respondents PRAYER: Writ Appeal filed under Clause 15 of the Letters Patent against the order passed in W.P. No.21881 of 2022 dated 05.12.2022. For Appellant : Mr. D. Ganesh Raj.
For Respondents : Mr. R. Kumaravel, Additional Government Pleader for R1.
Mr. P. Kumaresan, Additional Advocate General assisted by Mr. J. Lenin for R2 & R3.
J U D G M E N T
(Delivered by Dr. A.D. Maria Clete, J) This writ appeal is filed against the order dated 05.12.2022 passed by the learned Single Judge in W.P. No. 21881 of 2022. 2.
The appellant, an aspirant for the post of Sub-Inspector of Police under the recruitment notification issued by the Tamil Nadu Uniformed Services Recruitment Board (TNUSRB), participated in the written examination conducted 2/9
on 25.06.2022. However, he was not shortlisted for the next stages of the recruitment process.
3.
According to the appellant, the answers he had marked for Question Nos. 48, 91, and 130 were correct as per the initial answer key released by the respondent Board. Subsequently, in the final key published on 27.07.2022, the answers were altered, leading to the denial of marks and consequently, disqualification from the next stage of the recruitment-i.e., the physical test and certificate verification.
4.
The appellant filed the writ petition seeking a writ of Certiorarified Mandamus to quash the final answer key dated 27.07.2022 in respect of the aforementioned questions and consequently direct the respondent Board to permit him to participate in the physical test and certificate verification. 5.
The respondents, in their counter, contended that the answers marked by the appellant were not correct as per the final key, which had been prepared on the basis of an expert committee's recommendations. They emphasized that 3/9
representations were received from several candidates challenging the correctness of the provisional key, and therefore, a subject expert committee-constituted through the Department of Psychology-reviewed the questions and submitted its report, based on which the final key was released. 6.
The learned Single Judge, while dismissing the writ petition, held that the appellant had not demonstrated any patent error or manifest illegality in the final key. The learned Judge also noted that the appellant did not deny the correctness of the final answers but merely contended that his own answers were also correct -an argument which does not satisfy the threshold for judicial interference in matters of expert evaluation.
7.
The learned Judge placed reliance on the decisions of the Hon'ble Supreme Court in Kanpur University v. Samir Gupta [(1983) 4 SCC 309], Ran Vijay Singh v. State of U.P. [(2018) 2 SCC 357], and U.P. Public Service Commission v. Rahul Singh [Civil Appeal No. 5838 of 2018], which uniformly lay down the principle that judicial interference in academic matters, especially in objective-type exams, is warranted only when there is a glaring and indisputable error. 4/9
8.
In our view, the learned Single Judge has rightly declined to interfere. It is well settled that in the absence of demonstrable illegality or irrationality, the opinion of a duly constituted expert body cannot be substituted by judicial review. In the present case, the appellant does not dispute the correctness of the final key answers but contends that the answers originally selected by him were equally correct. This submission, by its very nature, would involve comparative evaluation and academic assessment, which is impermissible in writ jurisdiction unless the error is self-evident and patent.
9.
Further, the challenge to the composition of the expert body, on the ground that the Department of Psychology is not competent to opine on such questions, is misplaced. The evaluation of objective-type reasoning questions does not necessarily require subject-specific specialization; rather, it requires clarity in logic and assessment of reasoning patterns-areas well within the domain of the constituted committee.
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10.
Moreover, as observed by the Hon'ble Supreme Court in Ran Vijay Singh (supra), the entire selection process cannot be derailed on the ground that certain candidates are dissatisfied with the result. The larger public interest and the sanctity of the recruitment process must be preserved. 11.
We also find that the selected candidates, who would be directly affected if the appellant's plea were accepted, have not been impleaded as parties in the writ petition. This is a serious procedural lapse and further justifies the dismissal of the writ petition. In view of the above, we do not find any merit in the present appeal. The impugned order of the learned Single Judge warrants no interference. 12.
Accordingly, this Writ Appeal is dismissed. No costs. Consequently, the connected miscellaneous petition is closed.
(R.S.K., J) (A.D.M.C., J) 18.03.2025 ay To 6/9
1.The Principal Secretary to Government, Home Department, Fort St.George, Chennai - 600 009.
2.The Director General of Police/Chairperson, Tamil Nadu Uniform Services Recruitment Board, Anna Salai, Chennai - 600 002.
3.Member Secretary, Tamil Nadu Uniform Service Recruitment Board, Old Commissioner of Police Campus, Pantheon Road, Egmore, Chennai - 600 008.
4.The Section Officer, VR Section, High Court of Madras, Chennai.
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R.SURESH KUMAR, J and DR. A.D. MARIA CLETE, J ay W.A. No. 113 of 2023 and C.M.P. No. 1198 of 2023 18.03.2025 8/9
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