Join our WhatsApp Group
Latest News
Monday, October 12, 2026
Rajasthan High Court
Labour Law

Courts Cannot Overrule Expert Answer Key Unless Demonstrably Wrong: Rajasthan High Court Upholds Patwari Exam Key

Published: · NyayVidhan

A Division Bench of the Rajasthan High Court dismissed two intra-court appeals by candidates in the 2021 Patwari recruitment examination who challenged an Expert Committee's change of the answer key, for a question on where Saint Peepa's cave is, from ‘Toda’ to ‘Gagron’ (paras 7-9, 39). Courts may interfere with an answer key only where it is demonstrably wrong without inferential reasoning; where authentic texts conflict, the benefit of doubt goes to the examining body (paras 26, 36-37).

Courts Cannot Overrule Expert Answer Key Unless Demonstrably Wrong: Rajasthan High Court Upholds Patwari Exam Key

Judgment Intelligence

Petition Dismissed
Mahendra Kumar Jat & Ors. v. State of Rajasthan & Ors. (with Prakash Vishnoi & Anr. v. State of Rajasthan & Ors.)
2024:RJ-JP:26893-DB
D.B. Special Appeal (Writ) No. 986/2022 with D.B. Special Appeal (Writ) No. 782/2022
Court
Rajasthan High Court
Date of Decision
10 July 2024
Bench
Chief Justice Manindra Mohan Shrivastava and Justice Shubha Mehta
Relevant Acts & Sections
Constitution of India — Article 226
Final Outcome

Both appeals, D.B. Special Appeal (Writ) Nos. 986/2022 and 782/2022, were dismissed by a common judgment, leaving the Single Judges' orders and the revised key (‘Gagron’) for question 135 undisturbed; pending applications were also dismissed (paras 38-39).

Key holdings

  1. Without a rule permitting it, re-evaluation is not allowed; a demonstrably wrong key is the exception (paras 16, 26).
  2. Disputed keys go to an Expert Committee: a wrong key means reassessment; a vague or multiple-answer question is deleted (para 26).
  3. A writ court will not act as an expert where texts relied on by both sides point different ways (paras 34-35).
  4. A disputed historical fact is a matter for subject experts, not the court (para 35).
  5. In a case of doubt, the benefit goes to the examination authority rather than the candidate (paras 36-37).

Case explainer by NyayVidhan: an account of this judgment and the law it laid down, not the court's text. The judgment itself is the authoritative version.

Brief Facts

The Rajasthan Subordinate and Ministerial Service Selection Board advertised Patwari posts on 17.01.2020 and held the written examination on 23.10.2021 (para 4). Question 135 of Booklet Series-104C asked where Saint Peepa's cave is. The preliminary key gave ‘Toda’; after objections, an Expert Committee changed it to ‘Gagron’, and the final key followed on 25.01.2022 (paras 4, 8-9). Single Judges at Jodhpur (27.05.2022) and Jaipur (19.07.2022) declined to interfere on this question, and the two appeals were heard together at Jaipur (paras 2-3, 5-6). The appellants relied on an RTI reply, a municipal certificate, Archaeological Survey of India website content, two books and a 2008 examination key placing the cave at Toda (paras 11, 28).

Court's Findings

Surveying Supreme Court decisions, the Bench held that re-evaluation is impermissible without a governing rule, but where answers are demonstrably wrong the injustice must be undone (paras 16, 26). Disputed keys are to be examined by an Expert Committee; a demonstrably wrong key requires reassessment against the correct key, and vague questions or questions with several correct options are deleted (para 26). Judicial review is confined to exceptional cases where the key is wrong on its face, without inferential reasoning or rationalisation (paras 26, 36). The Committee relied on page 196 of an encyclopedia of Rajasthan history, which describes Saint Peepa as a ruler of Gagron who returned there and lived in a cave; page 532 of the same book lists Peepa's cave among the sights of Todaraisingh (paras 30-32). Another textbook produced by the respondents records that he visited Toda but finally settled in a cave at Gagron (para 33). Finding no unanimity on this historical fact, and that the saint stayed at both places, the Court declined to act as an expert; the inquiry had to stop there, and the case was at best one of doubt (paras 34-37).

Legal Principle

A court presumes an answer key to be correct and may interfere only in rare cases where the key is wrong on its face, without inferential reasoning or rationalisation. Where authentic texts conflict, the court will not substitute its own view for the Expert Committee's, and the benefit of doubt goes to the examining body (paras 26, 36-37).

Precedents Relied Upon

  1. Himachal Pradesh Public Service Commission v. Mukesh Thakur & Another (2010) 6 SCC 759
    Relied Upon Discussed at ¶ 17

    In the absence of any provision under the statute or statutory rules/regulations, the court should not generally direct revaluation of answer books.

  2. High Court of Tripura through the Registrar General v. Tirtha Sarathi Mukherjee & Others (2019) 16 SCC 663
    Relied Upon Discussed at ¶ 18, 22

    There is no legal right to revaluation without a provision for it, but in rare and exceptional cases, where a correct answer is beyond doubt yet treated as wrong, the writ court may still intervene.

  3. Manish Ujwal & Others v. Maharishi Dayanand Saraswati University & Others (2005) 13 SCC 744
    Relied Upon Discussed at ¶ 20-22

    Where experts unanimously found key answers demonstrably wrong, fresh evaluation with the correct keys was directed; students cannot suffer for the examining body's fault.

View all precedents (7)
  1. Guru Nanak Dev University v. Saumil Garg and Others (2005) 13 SCC 749
    Referred To Discussed at ¶ 24

    Noted among the decisions relied on in Richal: the university was directed to revaluate answers to eight questions with reference to key answers provided by CBSE.

  2. Rajesh Kumar & Others v. State of Bihar & Others (2013) 4 SCC 690
    Referred To Discussed at ¶ 24

    Noted among the decisions relied on in Richal: where the answer key was defective, the logical course was to correct the key and re-evaluate the scripts, not to hold a fresh examination.

  3. Bihar Staff Selection Commission and Others v. Arun Kumar and Others (2020) 6 SCC 362
    Referred To Discussed at ¶ 25

    Cited as a recent decision reiterating the settled principles on judicial review of answer keys.

  4. Vikesh Kumar Gupta and Another v. State of Rajasthan and Others (2021) 2 SCC 309
    Relied Upon Discussed at ¶ 25

    A court may not examine the correctness of questions and the answer key to reach a conclusion different from that of the expert committee.

NyayVidhan
Court Judgments · 3 min read
Decided: July 10, 2024 Chief Justice Manindra Mohan Shrivastava and Justice Shubha...
PDF
WhatsApp Telegram X / Twitter LinkedIn

✕

Try: POCSO, IBC, Electoral Bond, Article 370, NDPS Act, Bail Conditions, SC Contempt