Introduction:

The Delhi High Court, in Hanumant Lal Patel & Ors. v. Union of India & Ors., dismissed a batch of writ petitions challenging the Civil Services (Preliminary) Examination, 2023, specifically targeting Paper-II (CSAT), and in doing so reaffirmed the long-settled constitutional principle that judicial review in matters of competitive examinations is extremely limited. The petitions were heard and decided by a Division Bench comprising Justice Anil Kshetarpal and Justice Amit Mahajan, who declined to interfere with the expert-driven examination process conducted by the Union Public Service Commission. The petitioners, who were unsuccessful candidates in the Civil Services Preliminary Examination, approached the High Court after the Central Administrative Tribunal had already rejected their challenge. Their core grievance was that several questions in CSAT Paper-II allegedly exceeded the prescribed syllabus, which according to the examination rules was limited to a Class X standard. The High Court was thus called upon to determine whether courts could reassess the academic standard and content of competitive examination questions and grant consequential reliefs such as revised merit lists, fresh examinations, or policy relaxations in attempts and age, after the entire selection process had already concluded.

Arguments of the Petitioners:

The petitioners, represented by counsel Mr. Ritesh Kumar, advanced a detailed challenge premised on the alleged violation of the examination rules governing CSAT Paper-II. They contended that nearly eleven questions in the paper were drawn from Class XI and XII NCERT syllabi, particularly from advanced areas of mathematics and logical reasoning, despite the express stipulation that the paper would be confined to a Class X level. According to the petitioners, this deviation unfairly disadvantaged a large number of candidates who had prepared strictly in accordance with the notified syllabus and who lacked exposure to higher secondary concepts. It was argued that the impugned questions effectively altered the rules of the game after the examination had commenced, thereby violating the principles of fairness, transparency, and equality under Articles 14 and 16 of the Constitution. The petitioners further submitted that CSAT, though qualifying in nature, plays a decisive role in the elimination of candidates at the preliminary stage, and therefore even minor deviations from the syllabus could have disproportionate consequences on career prospects. On this basis, they sought extraordinary reliefs including preparation of a revised merit list after excluding the disputed questions, conduct of a fresh mains examination for affected candidates, or alternatively, grant of compensatory attempts and age relaxation to neutralise the alleged prejudice. They urged the Court to exercise its writ jurisdiction to correct what they characterised as a systemic academic error with far-reaching consequences.

Arguments of the Respondents:

The Union of India and the Union Public Service Commission, represented by counsel Mr. Balendu Shekhar, CGSC, along with other advocates, stoutly opposed the petitions, asserting that the challenge was legally untenable and institutionally misconceived. The respondents argued that determination of the nature, difficulty, and academic standard of questions in a competitive examination squarely falls within the domain of subject experts and expert bodies constituted for that purpose, and not within the realm of judicial adjudication. It was emphasised that upon receiving objections from candidates, the UPSC had constituted an independent Expert Committee comprising academicians and subject specialists, which had carefully examined each of the impugned questions and categorically concluded that all questions were within the prescribed syllabus and did not exceed the Class X standard. The respondents submitted that mere dissatisfaction or disagreement with the academic opinion of experts does not constitute a legal ground for judicial interference, unless perversity, mala fides, or manifest arbitrariness is demonstrated, none of which was even alleged, let alone proved. It was further argued that the entire Civil Services Examination, 2023 process had already been completed, including subsequent stages, and that courts do not grant infructuous or disruptive reliefs in large-scale public examinations, as doing so would unsettle finality, disrupt administrative certainty, and prejudice thousands of other candidates who were not before the Court. The prayer for additional attempts or age relaxation was also opposed on the ground that the examination rules are statutory in nature and policy-driven, and courts cannot rewrite or relax them in exercise of writ jurisdiction.

Court’s Judgment:

After considering the rival submissions and examining the record, the Delhi High Court dismissed the batch of petitions, holding that no case for judicial interference was made out. The Bench categorically observed that courts do not sit in appeal over the decisions of examining bodies nor do they possess the institutional competence to reassess academic content or substitute their own views for those of subject experts. Emphasising judicial restraint, the Court held that determination of the nature, standard, and difficulty level of questions in a competitive examination lies primarily within the province of experts, and judicial review is confined to examining whether the decision-making process is vitiated by illegality, irrationality, mala fides, or procedural impropriety. The Court noted that the UPSC had acted responsibly by referring the objections raised by candidates to an independent Expert Committee, which had conclusively opined that all the challenged questions fell within the prescribed syllabus. The Bench held that mere disagreement with this expert assessment, without demonstrating perversity or manifest error, cannot furnish a ground for invoking writ jurisdiction. The Court further observed that the entire selection process for Civil Services Examination, 2023 had already concluded, and it would be wholly inappropriate to grant reliefs that had become infructuous or that would disrupt settled outcomes in a nationwide examination involving lakhs of candidates. Rejecting the plea for compensatory attempts and age relaxation, the Court held that such reliefs are matters of policy governed by statutory rules, and courts cannot issue directions contrary to those rules, particularly when the academic basis of the challenge itself had failed. Accordingly, the High Court affirmed the CAT’s decision and dismissed the petitions, reinforcing the principle that academic evaluation and judicial review occupy distinct constitutional spheres.