Patwari Exam Normalisation Upheld: Rajasthan High Court

Selection Board May Normalise Multi-Shift Exam Marks Even If Not Advertised: Rajasthan High Court Upholds Patwari Result

Published: 18 October 2026 · NyayVidhan

The Rajasthan High Court dismissed writ petitions by candidates who sat the fourth shift of the Patwari Direct Recruitment Examination-2021 and challenged the Selection Board's decision to normalise marks after the examination. Rule 22 and Note 3 of Schedule II of the 2019 Rules let the Board prescribe the scheme, so normalisation was within the Rules though the advertisement did not mention it (paras 10, 13). The expert formula was applied uniformly, and a lower pass rate in one shift did not prove discrimination (paras 25-26, 30).

Key holdings

Note 3 of Schedule II lets the Board prescribe the scheme, including how the result is prepared (paras 10, 13).

Marks after normalisation are the marks obtained in the written examination for the Rule 28 merit list (paras 14-15).

The choice of formula is for the expert committee, whose unchallenged report is not reviewed in appeal (paras 23-24).

A lower selection ratio in one shift does not alone show hostile discrimination (paras 25-26).

Absent mala fides, the result is not open to interference in judicial review (paras 28-30).

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 Staff Selection Board held the Patwari Direct Recruitment Examination-2021 in four shifts on 23 and 24 October 2021, each with a different question paper (paras 1-2). By an order of 13.12.2021 it decided to normalise the marks; an expert committee recommended the V. Natarajan and K. Gunasekaran scaling formula, and the provisional result followed on 25.01.2022 (paras 2, 16). All the petitioners sat the fourth shift, on the evening of 24.10.2021 (para 3). They contended that normalisation was in neither the Rules nor the advertisement, that Rule 28 required raw marks, that moderation should have been used instead, and that their shift's selection ratio was about 21% below the first shift's (para 4).

Court's Findings

Normalisation is usual when a multi-shift examination uses different papers, as the petitioners accepted (opening of Point No. I). Rule 28 prescribes no other method, and Note 3 of Schedule II lets the Board prescribe the scheme, which includes preparing the result; nothing bars normalisation (para 10). Relying on Mahinder Kumar, where unnotified normalisation was approved, and Atul Kumar Dwivedi, the step was not outside the Rules (paras 11-13). Under Sanjay Singh and Atul Kumar Dwivedi, marks obtained in the written examination means marks after normalisation (paras 14-15). The Board acted on an expert report of 31.12.2021, re-checked on 07.02.2022, using a formula approved in Jai Singh (paras 16-21). That report was not challenged, and a writ court cannot sit in appeal over experts (paras 23-24). The formula was applied uniformly to all four shifts. Candidates were allotted alphabetically, women were placed on 23.10.2021 because of Karva Chauth, and Alwar and Dholpur candidates on 24.10.2021 because of local elections, so a lower fourth-shift result did not prove hostile discrimination (paras 25-26). No mala fides were alleged, and Articles 14 and 16 were not violated (paras 28-30).

Legal Principle

Where a recruitment examination is held in several shifts with different question papers, the selecting body may normalise marks on expert advice even if the advertisement was silent, when the Rules let it prescribe the scheme. A formula applied uniformly on expert advice is not interfered with in judicial review without mala fides or arbitrariness (paras 10, 24, 28).

Precedents Relied Upon

Mahinder Kumar & Ors. v. High Court of Madhya Pradesh & Ors. (2013) 11 SCC 87
Relied Upon Discussed at ¶ 11, 12, 13, 28
Normalisation of marks approved though the notification did not refer to it, the rules permitting the High Court to adopt a fair procedure; relied on for Note 3 of Schedule II of the 2019 Rules.
State of Uttar Pradesh & Ors. v. Atul Kumar Dwivedi & Ors. AIR 2022 SC 973
Relied Upon Discussed at ¶ 5, 6, 13, 15, 28
Reaffirms Mahinder Kumar; marks obtained in the written examination are the marks after normalisation; normalisation by the recruiting body is not lightly interfered with absent mala fides.
Sanjay Singh & Anr. v. U.P. Public Service Commission, Allahabad & Anr. (2007) 3 SCC 720
Relied Upon Discussed at ¶ 5, 14, 28
Valuation does not end with the examiner’s marks; marks awarded on moderation become the final marks obtained in the written examination.

View all precedents (12)

Jai Singh & Ors. v. State of Rajasthan & Anr. (2011) 2 WLC 46
Relied Upon Discussed at ¶ 6, 20, 21, 23, 25
Division Bench approved scaling by the V. Natarajan and K. Gunasekaran formula; a variance in results does not by itself fault a uniformly applied scaling method.
Union Public Service Commission v. M. Sathiya Priya & Ors. (2018) 15 SCC 796
Relied Upon Discussed at ¶ 24, 29
A court in judicial review does not sit in appeal over the decision of an expert committee.
Basavaiah (Dr.) v. Dr. H.L. Ramesh (2010) 8 SCC 372
Relied Upon Discussed at ¶ 24, 29
Courts have a very limited role over decisions of experts, especially when no mala fides are alleged.
Jairuddin Shaik v. State of Andhra Pradesh & Ors. 2021 (3) ALD 129
Distinguished Discussed at ¶ 5, 22
Cited by the petitioners; there a specific valuation procedure was prescribed in the advertisement and not challenged, so it did not help them.
U.P. Public Service Commission v. Subhash Chandra Dixit & Anr. (2003) 12 SCC 701
Referred To Discussed at ¶ 21, 28
Noted as the Supreme Court decision on which Jai Singh relied for scaling, and in the line of decisions followed in Atul Kumar Dwivedi.
Rajasthan Public Service Commission v. Ramesh Chandra Pilwal 1997 (2) RLW 1348 Raj.
Referred To Discussed at ¶ 22
Division Bench decision explaining normalisation, noted as relied on in Jairuddin Shaik.
Sunil Kumar & Ors. v. The Bihar Public Service Commission & Ors. 2016 (2) SCC 495
Referred To Discussed at ¶ 6, 28
Cited by the respondents; noted among the decisions on which Atul Kumar Dwivedi relied.
Gaurav Sharma & Anr. v. State of Rajasthan & Ors. SBCWP No. 4088/2022
Referred To Discussed at ¶ 6
Cited by the respondents in support of the normalisation; not discussed further in the judgment.
Anil Kumawat & Ors. v. Naveen Agarwal & Ors. 2012 (3) ILR (Raj) 164
Referred To Discussed at ¶ 6
Cited by the respondents in support of the normalisation; not discussed further in the judgment.

Statutory Provisions