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Delhi High Court Rejects Challenge to Civil Services (Preliminary) Examination 2023

 

Delhi High Court Rejects Challenge to Civil Services (Preliminary) Examination 2023

The Delhi High Court dismissed a batch of petitions filed by several unsuccessful aspirants of the Civil Services (Preliminary) Examination, 2023, who had challenged aspects of Paper-II, commonly known as the Civil Services Aptitude Test (CSAT). These candidates contended that approximately eleven questions in Paper-II were drawn from topics beyond the prescribed syllabus, which they argued was limited to Class X level. They sought relief in the form of a revised merit list, a fresh mains examination, or, alternatively, compensatory attempts and age relaxation, on the basis that the inclusion of allegedly out-of-syllabus questions unduly disadvantaged them.

A Division Bench of the High Court, composed of two judges, emphasised that judicial review of competitive examinations is extremely limited. The court stated that it cannot sit in appeal over the opinion of expert bodies responsible for framing and evaluating examination content, nor can it substitute its own academic judgment for that of subject experts. The Bench noted that following the objections raised by candidates, the Union Public Service Commission had constituted an independent Expert Committee, which reviewed the disputed questions and concluded that they were within the scope of the prescribed syllabus. Given this expert assessment, the court held that mere disagreement with the academic evaluation by the petitioners, absent any demonstration of perversity or manifest error by the expert committee, could not justify judicial interference.

In reaching its decision, the High Court explained that the entire process for selection through the Civil Services Examination 2023 had already been completed. It underscored that courts do not exercise writ jurisdiction to grant reliefs that would be rendered infructuous by the conclusion of the selection process for large-scale public examinations. The court further observed that the prayers for additional attempts or age relaxation were untenable in law because the statutory rules governing the examination, including eligibility and attempt limits, are policy decisions outside the scope of judicial revision, particularly where subject experts had clearly opined that the questions in issue were not beyond the syllabus.

The Delhi High Court reiterated its consistent position that the determination of the nature and standard of questions included in competitive examinations falls within the province of the examining authority and its expert committees. It emphasised that courts lack the institutional competence to re-examine academic issues that are entrusted to those experts unless there is a clear miscarriage of justice. The court’s ruling, therefore, upheld the earlier decision of the Central Administrative Tribunal, which had also dismissed the candidates’ challenge on similar grounds.

By dismissing the petitions and refusing to intervene in the examination process at this advanced stage, the Delhi High Court affirmed the limited role of judicial review in challenges pertaining to competitive examinations. The judgment emphasises respect for the expertise of examination authorities and clarifies that disagreements with academic content, absent clear evidence of irregularity or error, are insufficient to warrant revision of examination outcomes or alteration of prescribed statutory rules.

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