Introduction:
In the case titled Anusha Gupta & Ors v. National Testing Agency (Through the Director) & Ors, the Delhi High Court recently dealt with an important dispute concerning allegations of irregularities in the conduct of the Joint Entrance Examination (JEE) Main 2025. The petitioners, two candidates who had appeared for the examination, approached the Court seeking various directions, including permission to participate in JEE (Advanced) 2025, release of their actual results for both sessions based on what they described as their correct and original response sheets, and a directive to the National Testing Agency (NTA) to adopt a more robust system for tracking digital footprints to ensure fairness and transparency. The case attracted attention because of the seriousness of the charges of manipulation and tampering in the official records, which directly touched upon the integrity of one of the country’s most competitive and prestigious examinations. However, after detailed examination and a technical enquiry conducted by experts, the Court found that the petitioners had failed to substantiate their allegations with credible evidence. Instead, the Court noted significant gaps in their digital records and drew an adverse inference against them. Consequently, Justice Vikas Mahajan of the Delhi High Court not only dismissed their petitions but also imposed a cost of ₹30,000 on each petitioner, payable to the Chief Justice Disaster Relief Fund 2025 of the Himachal Pradesh High Court, as a deterrent against what the Court described as “unscrupulous litigants” approaching the judiciary with unclean hands.
Petitioners’ Arguments:
The petitioners, including Anusha Gupta, approached the Court with serious grievances against the National Testing Agency (NTA), which conducts the JEE Main examination across the country. They contended that their scorecards had been manipulated and tampered with after they had initially accessed them online. It was their claim that the scores originally published for them in Session I were altered following the release of the final scorecard after Session II. One of the petitioners further alleged that even his attempt during Session II was marred by irregularities, which placed him at a disadvantage when compared with other candidates. The core thrust of their argument was that there had been either a breach or a deliberate manipulation of the official records maintained by NTA, and that they had been unfairly deprived of their rightful scores.
The petitioners argued that they were entitled not only to the restoration of their original scores but also to be allowed to participate in the JEE (Advanced) 2025 examination, which is the gateway to securing admission into the Indian Institutes of Technology (IITs). They claimed that the system adopted by NTA was insufficient to track breaches or ensure transparency in the examination process. Accordingly, they sought directions to NTA to establish a more robust system, including the use of advanced digital watermarking and tracking technologies, which would enable better monitoring of digital footprints. By pressing this plea, the petitioners attempted to highlight what they described as systemic flaws in the current system of examination management.
The petitioners emphasized that the scorecards they relied upon had been downloaded directly from the official website of the NTA, thereby giving them authenticity. They further contended that the discrepancies in their results were not the result of their actions but rather of manipulation at the end of the authorities. They placed heavy reliance on their ability to produce files containing their scorecards from their laptops and invited the Court to treat these as proof of their claims. In their view, the expert scrutiny should have vindicated them and exposed the lapses of NTA.
Respondents’ Arguments:
The respondents, represented by the National Testing Agency (NTA), opposed the petitioners’ claims with equal seriousness. They maintained that the allegations of manipulation and tampering were baseless and unsupported by any credible evidence. According to NTA, the final composite scorecards published for the petitioners reflected their actual performance in the examinations, and there was no scope for doubting the integrity of the official records.
NTA emphasized that, at the request of both parties, the matter had been referred to experts for technical scrutiny. The National Cyber Forensic Laboratory (NCFL) experts examined the laptops of the petitioners and reported that although files containing the scorecards could indeed be located on their devices, the browsing history for the relevant time period was conspicuously missing. This missing data was critical, since it would have provided the necessary context as to whether the scorecards had genuinely been downloaded from the official website at the time claimed by the petitioners. The absence of such vital browsing history could not, according to NTA, be explained away as a mere accident or random occurrence.
It was further argued by NTA that the petitioners, having failed to preserve the relevant digital records or to explain the absence of crucial logs, could not expect the Court to disregard the presumption in favour of official records. Under Section 114 of the Indian Evidence Act, 1872, official records maintained by public authorities carry a presumption of correctness unless compelling evidence is produced to the contrary. In the present case, NTA argued, no such compelling evidence had been furnished by the petitioners.
NTA also rejected the argument that its systems lacked robustness. It maintained that its examination system, including result compilation and publication, was foolproof and designed to withstand manipulation. It was the petitioners, NTA suggested, who had failed to demonstrate good faith, and their litigation was an attempt to gain undue benefit by casting aspersions on the credibility of a national-level examination.
Court’s Observations and Judgment:
After considering the submissions of both sides and perusing the expert report of NCFL, the Court proceeded to make significant observations. Justice Vikas Mahajan noted that the entire exercise of involving technical experts was undertaken at the joint request of the parties, with the petitioners themselves expressing confidence in the genuineness of the documents they relied upon. However, the findings of the expert body did not support the petitioners’ case. The experts confirmed the presence of files containing the scorecards on the petitioners’ laptops but categorically pointed out that the browsing history for the relevant period was absent.
The Court observed that the absence of browsing history for the specific period in question was not something that could be casually ignored. Browsing history is automatically generated by internet activity, and its complete absence during the relevant timeframe could not be assumed to be a mere random occurrence. The petitioners had neither preserved the relevant logs nor provided any convincing explanation for their absence. In such circumstances, the Court held that it was justified in drawing an adverse inference against the petitioners, as the missing data cast serious doubts on the authenticity of their claims.
The Court further rejected the petitioners’ assertion that their scorecards had been downloaded from the official NTA website. On the contrary, NTA had produced official records showing the petitioners’ percentiles as recorded in the final composite scorecards, and there was no credible reason to doubt their accuracy. Justice Mahajan observed that the petitioners had failed to establish their bona fides, and that no exception could be carved out in their favour.
A particularly significant aspect of the Court’s reasoning was its reliance on the presumption of correctness attached to official records under Section 114 of the Indian Evidence Act. The Court made it clear that unless strong and convincing evidence is produced to the contrary, the authenticity of official records cannot be lightly questioned. Since the petitioners had failed to provide such evidence, their claims necessarily had to fail.
In addition to dismissing the petitions, the Court took the unusual step of imposing costs of ₹30,000 on each petitioner. Justice Mahajan reasoned that such costs were necessary not only because of the abundant efforts expended by several government agencies to scrutinize the allegations but also to deter unscrupulous litigants from approaching the Court with unclean hands. The Court directed that the costs be deposited within two weeks towards the Chief Justice Disaster Relief Fund 2025, established by the Chief Justice of the Himachal Pradesh High Court.
The judgment thus concluded with a strong message that litigants who attempt to misuse the judicial process without adequate basis will face financial consequences, and that the credibility of national-level examinations cannot be allowed to be undermined without compelling evidence.