Uttar Pradesh Subordinate Service Selection Commission vs Ashok Yadav & Ors

Case Snapshot

Case Name: Uttar Pradesh Subordinate Service Selection Commission v. Ashok Yadav & Ors.
Citation: 2026 INSC 991
Bench: Justice Manoj Misra and Justice Vijay Bishnoi
Date of Judgment: September 9, 2026
Area of Law: Education Law, Judicial Review, Answer Key Challenges

The Judgment in One Line

Supreme Court allows appeal, sets aside High Court's review order that awarded marks for option 'C', holding Commission's answer key (option 'B') correct.

Why this Judgement Matters

This judgment reinforces the limited scope of judicial review in challenges to answer keys of public examinations. It clarifies that candidates must demonstrate a glaring, self-evident error, not one requiring inferential reasoning. The Court reiterated that the benefit of doubt goes to the examining body, not the candidate. The ruling will curb unnecessary interference by courts in examination processes, ensuring finality and certainty in results. It also provides guidance on when a question can be said to have two correct answers, permitting exclusion of the question.

Background

The Commission advertised 3,133 posts of Village Development Officer in 2016. A written test was held, provisional answer key published, objections considered, and a revised answer key issued. The result was declared in 2018. The respondent filed a writ petition seeking one mark for his answer to a question: "Which of the following is not correctly matched?" He chose option 'C' (Humayun Nama – Humayun), arguing that Humayun Nama was authored by Gulbadan Begum, not Humayun. The Commission had chosen option 'B' (Shahjahan Nama – Mohammad Tahir), as Shahjahan Nama is about Shahjahan, not Mohammad Tahir. The Single Judge dismissed the writ on laches; the Division Bench dismissed the appeal; but the High Court allowed a review, relying on an expert report that said both options could be correct depending on the parameter. The Commission appealed.

Issues Before the Court

Whether the High Court was justified in interfering with the Commission's decision to treat option 'B' as the only correct answer.
Whether the question suffered from a glaring mistake warranting judicial interference.
Whether the expert report relied on by the High Court was categorical that option 'C' was the only correct answer.

What Did the Supreme Court Hold?

Limited Scope of Judicial Review

The Court reiterated the principles from Ran Vijay Singh v. State of U.P.:
Courts should not re-evaluate answer sheets; they lack expertise.
Presumption of correctness attaches to the answer key.
Onus is on the candidate to show a glaring mistake, not one requiring inferential reasoning.
Benefit of doubt goes to the examining body.
The Court also relied on U.P. Public Service Commission v. Rahul Singh.

No Glaring Mistake in the Question or Answer

The question did not specify the parameter for pairing. Absent a parameter, a commonsense approach of pairing the book with the subject (the person the book is about) is permissible.
Applying that approach, option 'B' is incorrect (Shahjahan Nama is about Shahjahan, not Mohammad Tahir). Thus, option 'B' is the correct answer.
The respondent assumed that pairing had to be by authorship, which was not stated. That was an inferential leap, not a glaring error.

Expert Report Not Categorical

The expert report stated that if pairing is by authorship, option 'C' is correct; if by subject, option 'B' is correct. It did not declare option 'B' incorrect.
The High Court erred in treating the report as conclusive that option 'C' was correct.

Review Jurisdiction Misused

The High Court's review order was unsustainable because it interfered with the Commission's decision without meeting the high threshold for judicial review.

Key Legal Principles

Judicial review of answer keys is limited to glaring, self-evident mistakes that require no inferential reasoning.
Presumption of correctness attaches to the answer key; the onus is on the candidate to prove error.
Benefit of doubt goes to the examining body, not the candidate.
Courts lack expertise in academic matters and should not re-evaluate answer sheets.
If a question is ambiguous and has two possible correct answers, the court may exclude the question; but if the question is clear and has only one correct answer, interference is unwarranted.
Laches is a ground for rejecting challenges to examination results.
Review jurisdiction cannot be used to re-agitate the same issues without demonstrating an error apparent on the face of the record.

Important Precedents

Ran Vijay Singh v. State of U.P. – Laid down principles limiting judicial review of answer keys; presumption of correctness; onus on candidate.
U.P. Public Service Commission v. Rahul Singh – Reiterated that courts must exercise restraint and be reluctant to entertain answer key challenges.
Siddhi Sandeep Ladda v. Consortium of National Law Universities – Distinguished; that case involved academicians acting arbitrarily, whereas here the Commission's approach was reasonable.

Practical Impact

For Advocates: This judgment reinforces that challenges to answer keys must meet a high threshold. Advocates should focus on demonstrating a glaring, self-evident error, not an inferential one.
For Future Litigation: The ruling will be cited to oppose interference in examination matters, ensuring finality and certainty in results.
For Examining Bodies: The judgment provides comfort that their answer keys will be presumed correct unless a blatant error is shown.

Lawcurb Quick Insight

The expert report was equivocal—it said both options could be correct depending on the parameter. The High Court mistakenly treated it as declaring option 'B' incorrect. This highlights the danger of relying on equivocal expert opinions in judicial review.

Lawcurb Practice Note

Advocates challenging answer keys should first check if the question specifies the parameter for matching. If not, the examining body's commonsense approach will likely prevail. Only a clear, self-evident error will justify interference.

Remember this Ratio

Judicial review of answer keys is permissible only for glaring mistakes; the benefit of doubt goes to the examining body, not the candidate.

Final Outcome

Civil Appeal allowed; impugned judgment of the High Court set aside.
Commission's answer key (option 'B') upheld as correct.
No interference with the Commission's decision.
Pending applications disposed of.

Lawcurb Verdict

This judgment is a significant reaffirmation of the limited role of courts in academic and examination matters. By upholding the Commission's answer key, the Court prevents uncertainty and delays in examination results. The ruling serves as a caution to candidates and courts alike: answer key challenges must meet a high threshold of glaring error. A well-reasoned judgment that balances the need for finality with the rare cases of genuine error.

Exam Lens

Question 1: Discuss the scope of judicial review in challenges to answer keys of public examinations. What are the guiding principles laid down in Ran Vijay Singh v. State of U.P.?

Answer: The Supreme Court in Ran Vijay Singh laid down several principles: (i) courts should not re-evaluate answer sheets; they lack expertise; (ii) presumption of correctness attaches to the answer key; (iii) onus is on the candidate to demonstrate a glaring mistake, not one requiring inferential reasoning; (iv) benefit of doubt goes to the examining body; (v) courts may interfere only if the mistake is apparent without any inferential process. In UP Subordinate Service Selection Commission v. Ashok Yadav, the Court applied these principles, holding that the High Court erred in interfering where the question did not specify the parameter for pairing and the Commission's commonsense approach was reasonable.

Question 2: When can a court exclude a question from evaluation in an examination? Explain with reference to the present judgment.

Answer: A court may exclude a question if it is demonstrated that the question itself is incorrect, or there are two correct answers when only one is to be chosen. In the present case, the question did not specify the parameter for pairing. The expert report said both option 'B' and 'C' could be correct depending on the parameter. However, the Court held that absent any specified parameter, the commonsense approach of pairing book with subject is permissible, and under that approach, only option 'B' is correct. Thus, there were not two correct answers; the question was not incorrect. The Court refused to exclude the question.

Question 3: What is the significance of laches in challenges to examination results? How did the Court address it?

Answer: Laches is a ground for rejecting challenges to examination results. In the present case, the writ petition was filed much after the declaration of the result. The Single Judge dismissed it on laches. Although the High Court allowed the review, the Supreme Court held that the writ court ought not to have interfered, especially when the challenge was stale. The Court emphasized that courts must be strict in condoning laches in such matters due to the consequences for the entire examination process.

This report is prepared by Lawcurb for educational and informational purposes only. It is a concise summary of the judgment and should not be construed as legal advice. Readers are encouraged to refer to the original judgment before relying on any legal proposition.