Courts Must Not Act as Subject Experts: Punjab & Haryana High Court Dismisses Challenge to PGT Chemistry Answer Key

The Judicial Arm Should Not Reach Where Its Grasp Is Neither Necessary Nor Appropriate - In a significant ruling Punjab and Haryana High Court dismissed an appeal challenging the answer key of the PGT Chemistry screening test conducted by the Haryana Public Service Commission (HPSC). The Division Bench of Justices Sanjeev Prakash Sharma and Meenakshi I. Mehta refused to interfere with the findings of the Expert Committee, reiterating that courts must exercise judicial restraint in academic matters.

“The Judicial Arm Should Not Reach Where Its Grasp Is Neither Necessary Nor Appropriate,” observed the Court, emphasizing that technical evaluation is best left to experts and judicial intervention should be avoided unless there is a clear case of illegality or mala fide intent.

The appeal arose from the screening test held on October 13, 2024, for the recruitment of Post Graduate Teachers (PGT) in Chemistry. Following the test, the final answer key was published on October 28, 2024, which led to objections from several candidates, particularly regarding Question No. 82.

The petitioners argued that the correct answer to Question No. 82 was “Peroxy Acyl Nitrate” (Option C), which had previously been accepted as correct in similar exams conducted by the Haryana School Education Board. However, the HPSC’s revised answer key marked “None of the Above” (Option D) as the correct answer, affecting the rankings of several candidates.

Challenging this decision, the petitioners approached the High Court through a writ petition (CWP-29861-2024), which was dismissed by a Single Judge. Subsequently, they filed a Letters Patent Appeal (LPA-322-2025) before the Division Bench, contending that the expert review process was flawed and that their exclusion from the merit list was unfair.

The High Court reaffirmed the well-established principle that courts should not interfere with expert academic decisions unless an answer key is "palpably and demonstrably wrong."

“It is a settled law that the concerned examiner or the expert would have the expertise to reach a particular conclusion,” observed the Court. “If an expert committee, whose credentials are not under question, has examined the matter and reached a decision, the Court should not substitute its own views.”

Referring to Ran Vijay Singh v. State of U.P. (2018) 2 SCC 357, the Court held that judicial intervention in academic matters should be rare and only warranted in cases of clear and egregious errors.

“The evaluation process is an exercise of specialized discretion entrusted to the examiner, and it is not the writ Court’s role to encroach upon this domain,” the Bench stated. “If the judiciary starts questioning the wisdom of experts in specialized fields, it will disrupt the balance of institutional roles.”

The High Court also relied on Himachal Pradesh Public Service Commission v. Mukesh Thakur (2010) 6 SCC 759, where the Supreme Court categorically held that courts should not evaluate question papers unless the error is "palpable and demonstrable."

Dismissing the argument that a different answer had been accepted in previous examinations, the Court stated: “Merely because an earlier examination treated an answer differently does not mean that the current key is incorrect. Two wrongs do not make a right.”

Rejecting the plea, the High Court upheld the validity of the answer key finalized by the Expert Committee, holding that there was no demonstrable error or mala fide intent in the revision process.

“The entire basis of an examination is that we have faith in our examiners and experts,” the Court remarked. “If a different view is taken in every case, all competitive examinations would be under a perpetual scanner, and there would be no finality to selection processes.”

The appeal was dismissed, and the HPSC’s selection process was upheld.

This ruling reinforces the judiciary’s reluctance to interfere in academic matters and affirms that technical questions must be left to subject matter experts. By upholding the integrity of the selection process, the Punjab & Haryana High Court has set a precedent that prevents unnecessary litigation from disrupting recruitment procedures.

Date of Decision: March 3, 2025