Simplified Explanation of the Judgment

The Patna High Court in 2021 decided an important case concerning the evaluation of the 31st Bihar Judicial Services (Preliminary) Examination, conducted by the Bihar Public Service Commission (BPSC). The petitioner, a candidate in the exam, claimed that the Commission had provided incorrect answers to three questions in the Set-D question paper—Question Nos. 58, 126, and 133.

According to the petitioner, the BPSC marked “B” as correct for Q.58, whereas the right answer was “C.” Similarly, for Q.126, “C” was marked correct instead of “D,” and for Q.133, “C” was marked correct instead of “B.” He argued that due to these errors, he was wrongly declared unsuccessful and excluded from the list of qualified candidates.

After the preliminary exam, the Commission published provisional answer keys on its website on 19 December 2020. Candidates were invited to file objections against any answer by 31 December 2020 (5 PM). The BPSC made it clear that only those objections received within the deadline and in a prescribed format (sealed envelope mentioning advertisement number) would be examined by an expert committee.

However, the petitioner did not raise any objection within the stipulated time. He claimed that due to the COVID-19 lockdown, he was residing in a village area with poor internet access and was unaware that the answer key had been published online. Therefore, he could not submit objections before the deadline.

The Commission, on the other hand, argued that the procedure followed was standard across all examination bodies, ensuring transparency and fairness. Every candidate had equal opportunity to challenge the provisional key, and the petitioner’s failure to do so could not be excused.

The Court observed that the Commission had followed an established and fair procedure. Candidates were duly notified through the website, and it was their responsibility to remain vigilant. The Court emphasized that in the digital era, even rural areas have sufficient internet access, and a candidate aspiring for a judicial post should exercise diligence.

Further, the Court noted that the petitioner had filed the writ petition after the final result was declared. Allowing such belated challenges would cause administrative uncertainty and defeat the purpose of the objection process.

Importantly, the Court relied upon the Division Bench judgment in Ashutosh Kumar Jha & Ors. v. State of Bihar & Ors. (LPA No. 1235 of 2016). In that case, it was held that High Courts, while exercising writ jurisdiction, cannot re-evaluate or substitute the opinion of an expert body on academic matters such as answer key correctness, unless the decision is “obnoxious” or perverse.

The Court observed that it was not an appellate forum to reassess the correctness of the answers. The evaluation of answers falls within the domain of experts, and judicial interference should be minimal. Since the petitioner had neither raised objections within the prescribed time nor shown any perversity or illegality in the expert body’s decision, his challenge had no merit.

Consequently, the Patna High Court dismissed the writ petition, holding that there was no valid ground to interfere with the results of the BPSC Judicial Services Preliminary Examination.

Significance or Implication of the Judgment

This judgment carries significance for both examination authorities and candidates:

• It reaffirms that candidates must adhere to published procedures and deadlines when objecting to answer keys or exam results. Courts will not entertain belated claims.
• It emphasizes judicial restraint in academic and expert matters. The judiciary will not act as an appellate body over expert evaluations unless decisions are manifestly wrong.
• It encourages transparency and uniformity in public recruitment processes, as BPSC’s objection mechanism was upheld as fair and standard.
• For candidates, it underlines the duty to remain vigilant—especially in the digital age where examination notices are primarily disseminated online.
• The ruling helps preserve the integrity and finality of competitive examinations by preventing endless litigation over answer keys.

Legal Issue(s) Decided and the Court’s Decision

• Whether a candidate can challenge examination results after failing to file objections within the prescribed time?
  • Decision: No. Once the opportunity to object has lapsed, candidates cannot later challenge the results through a writ petition.
  • Reasoning: The Commission followed a transparent procedure, and candidates had adequate notice through the website.
• Can the High Court review or alter the correctness of answer keys finalized by experts?
  • Decision: No. The Court cannot substitute the judgment of subject experts unless the answer is demonstrably wrong or the decision is perverse.
  • Reasoning: Following Ashutosh Kumar Jha v. State of Bihar, judicial review is limited to procedural fairness, not academic evaluation.
• Whether COVID-19 restrictions excuse failure to file objections?
  • Decision: No. The petitioner was expected to remain alert and use available means to stay informed about the process.
  • Reasoning: The notice was publicly available online; therefore, personal inconvenience cannot override an established legal process.

Judgments Referred by Parties

• Ashutosh Kumar Jha & Ors. v. State of Bihar & Ors., LPA No. 1235 of 2016 (Patna High Court)

Judgments Relied Upon or Cited by Court

• Ashutosh Kumar Jha & Ors. v. State of Bihar & Ors., LPA No. 1235 of 2016 (Patna High Court) — Standard on judicial review in examination matters.

Case Title

Petitioner v. State of Bihar & Ors.

Case Number

Civil Writ Jurisdiction Case No. 8106 of 2021

Citation(s)

2021(2) PLJR 322

Coram and Names of Judges

Hon’ble Mr. Justice Shivaji Pandey
Hon’ble Mr. Justice Partha Sarthy

Names of Advocates and who they appeared for

• Mrs. Manisha Pandey, Ms. Shweta Pandey, Mr. Vishwanath Pandey — for the Petitioner
• Mr. G.P. Ojha, GA-7 — for the State
• Mr. Sanjay Pandey — for the Bihar Public Service Commission

Link to Judgment

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