M.Anantharaj v. Teachers Recruitment Board

JUDGMENT (JUDGMENT MADE BY V.LAKSHMINARAYANAN, J.) These two writ appeals assail the common order passed by the learned Single Judge in W.P.No.49806 of 2025 & W.P.No.49815 of 2015 dated 02.01.2026. The writ petitioners are the appellants. The respondent had issued a notification inviting applications from the eligible candidates for the post of PG Assistants including Physical Education Director Grade-I. The total number of vacancies was 101. The petitioners claim that they were eligible and submitted their applications. The respondent conducted a written examination on 12.10.2025. The examination consisted of two parts. Part-A dealt with Tamil Eligibility Test and Part-B with respect to the subject knowledge. The results of the examination were published on 27.10.2025. The petitioners had secured pass marks in Part-A and had secured the following marks in Part-B: 1st Petitioner (MBC category) : 91 marks 2nd Petitioner (SC category) : 93 marks 3rd Petitioner (ST category) : 92 marks 4th Petitioner (BC category) : 89 marks 5th Petitioner (SC category) : 89 marks 6th Petitioner (BC category) : 93 marks The petitioners state that when the key answers were released, they discovered that in the subject knowledge examination '#' symbol had been affixed for question Nos.39, 40, 95, 97, 99, 149, 167 and

¶180The petitioners state that the respondent had given the '#' marks to the aforesaid questions and without reasons or justification awarded 8 marks to all the candidates irrespective of whether the candidates had attempted these questions or whether the candidates answered these questions correctly or erroneously. The petitioners state the they had attempted all the eight questions and had given correct answers. Hence, they filed the writ petitions challenging the methodology adopted by the respondent of giving marks to all the candidates who had appeared in the examination. The learned Single Judge came to a conclusion that the methodology adopted by the respondent in granting marks to all the candidates cannot be considered is rational and does not require interference. Challenging the same, the present writ appeals. We heard Mrs.Nalini Chidambaram, learned Senior Counsel appearing for Mrs.Uma for the appellants and Mr.R.Neelakandan, learned Additional Advocate General assisted by Mr.C.Kathiravan, Standing Counsel for the respondent. Mrs.Nalini Chidambaram urged that the questions for which '#' marks had been given were correct and the respondent had erroneously held that the eight questions had been wrongly framed. She states that the petitioner had given the correct answers for the questions so asked and therefore, they have been deprived of being placed on par with the persons who have not been even attempted the questions. Per contra, Mr.R.Neelakandan, urged that the Board had notice that the eight questions had been wrongly framed and hence, taken a decision to award marks for those questions to all the candidates irrespective of the fact whether the candidates have attempted the questions and not. He states that on account of granting marks to everyone uniformly the level playing field does not been affected. We have carefully considered the submissions on both sides and have gone through the records. The position of law has been reiterated and settled by the Supreme Court in Vikesh Kumar Gupta and Another v. State of Rajasthan and Others, (2021) 2 SCC 309. The Supreme Court held that Constitutional Courts should not re-evaluate question papers or answer keys unless they are demonstrably incorrect and perverse. It pointed out that in matters of academic evaluation, particularly, in competitive examinations, the judiciary should not substitute its own view for those of experts unless the answer keys are patently erroneous. It held that the courts, while exercising the power of judicial review, should not convert themselves into examiners and re-assist the answers. Such an exercise by the constitutional courts would only lead to kias and uncertainty and thereby take away the very sanctity of the examination. It has also been held that when a body of experts have verified the questions or answers, due defference must be given to the same and should be taken to be correct. The Supreme Court had referred to the following judgments of itself in order to come to the conclusion: Himachal Pradesh Public Service Commission v. Mukesh Thakur and Another, (2010) 6 SCC 759; Basavaiah v. H.L. Ramesh and Others (2010) 8 SCC 372 Ran Vijay Singh and Others v. State of U.P. and Others, (2018) 2 SCC Richal and Others v. Rajasthan Public Service Commission and Others, (2018) 8 SCC 81 This judgment has held that the role of the judiciary should be to maintain the integrity of the administrative process without over stepping into areas which require specialised knowledge and expertise. Due deference should be given to bodies like Public Service Commission and recruitment boards like the respondent and the expert commttees in conducting and finalising the examination. Such a direction has been issued in order to ensure that there are no delays in administrativeappointments due to litigation. The judiciary restrant requires that the court limits its power and defers to the expertise of committees who have finalised the questions and answers especially in matters relating to technical or sepcialised fields. The booklet containing the key answers outlines the correct answers for the questions post in the examination. When the body of experts have come to the conclusion that the eight questions had been wrongly framed, it is not for this court to decide as to whether such a conclusion is erroneous. the respondent by granting marks uniformly to all the candidates has ensure level playing field to all the competitors. Level Playing Field refers to a state of formal equality of opportunity. Wherein, no competitors gains an unfair advantage over another. It refers to a state where everyone is subject to the same set of rules. The basis for level playing field are equality of rules and the absence of bias. Equality of rules implies that all those taking the competitive examination played by the same standards but it does not ensure equal outcome for everyone. Equality of rules alone is not sufficient. In addition to the same, in order to ensure level playng field, there should be absence of bias. In otherwords, the playing field should be levelled "without their being any external interference or arbitrary criteria affecting a person's ability to compete fairly". The ground on which, an action can be challenged is if it fails the test of reasonableness as enshrined under Article 14 of the Constitution of India. The framing of clear questions in an examination is one of the foundational requirements of a fair, transparent and objective selection process. If the questions framed are ambiguous manner, without any clarity, it will affect the level playing field contemplated set forth above. Clear questions in a subject knowledge examination tests the candidates knowledge, ability and analytical skills.it does not throw them to the situation of guessing what the examiner internded to test them on. When a question is framed in an ambiguoud manner, it would lead to multiple interpretations giving an unfair advantage to certain persons. If a question is vague or ambiguously framed, the purpsoe of holding the examination is lost. The examinations ceases to be a dependable to for identifying the best qualified person. This position has been clearly laid down by the court in Kanpur University v. Sameer Gupta. The Supreme Court held that a question paper must be accurate and unambiguous so that no reasonable body of men well versed in eh subject would disagree on the correct answer. Similarly in objective type test court held examiners must ensure that the question of ambiguous import are not framed. This verdict shows that the burden is on the authorities like th e respondent who conduct the recruitment tests .the respondent themselves have admitted that the questions which Chidambaram states have been correctly framed or wrong. In order to ensure a level playing field, all the candidates have been given marks in the examination. In an examination everyone starts with '0' (zero) marks and on the absis of their performance, they are graded. By granting a mark to all those who have appeared in the examination, the resondent have not granted any unfair advantage to one set of persons as againt another. While we found upon an expert body like the respondent for having committeed such an error in an examination for recruitment, when they have equalised the level by granring marks to everyone, we are of the view that the same has not resulted in any adverse consequences. Though the petitioners assert that they had answered the questions it is posible that certain candidates finding that th equestions had not been properly framed would have been confused and avoided and answering the same. Such candidates cannot be put to disadvantage. It was those circumstances that ht respondten have taken a decision to grant the marks to all the candidates this decision in our view in the light of the above discussion cannot be held to be irrational. On the contrary we are of the view that by the act of graning marks for the eight ambiguous question to all the question,s the respondent have levelle the playing field. In the light of this disucssion, the wri tappeals are dismissed. No costs. R.S.K., J. V.L.N., J.

28.01s.201 & 2026 nl

R.SURESH KUMAR, J. AND V. LAKSHMINARAYANAN. J. nl

28.01s.201 & 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 28.01s.201 & 2026 CORAM: THE HONOURABLE MR. JUSTICE R.SURESH KUMAR AND THE HONOURABLE MR. JUSTICE V. LAKSHMINARAYANAN 1.M.Anantharaj 2.A.Gopalakrishnan 3.K.Chinnamani 4.V.S.Gugan 5.V.Dhanalakshmi 6.S.Ramachandran ... Appellants in both W.As. Vs. Teachers Recruitment Board, Represented by its Secretary, 3rd and 4th Floor, Puratchi Thalaivar, Dr.MGR Centenary Building, Perasiriyar Anbazhagan Kalvi Valagam, DPI Complex, College Road, Chennai – 600 006. ... Respondent in both W.As. COMMON PRAYER: Writ Appeals filed under Clause 15 of the Letters Patent to set aside the common order of this Court dated 02.01.2026 passed in W.P.No.49815 of 2025 & W.P.No.49806 of 2025. For Appellants in both W.As. : Mrs.Nalini Chidambaram, Senior Counsel for Mrs.Uma For Respondents in both W.As. :Mr.R.Neelakandan, Additional Advocate General, Assisted by Mr.C.Kathiravan, Standing Counsel