Mechanism Reflects Structured Approach To Finalisation Of Answer Key: Allahabad High Court Sets Aside Single Judge Order To Revise CLAT Merit List

The Court held that the institutional mechanism employed by the Consortium of National Law Universities—which includes rigorous scrutiny by subject experts and an Oversight Committee—must be respected.

The Court noted that since the final answer keys were based on plausible academic interpretations, the previous interference by the Single Judge, while well-intentioned, overstepped the settled legal boundaries governing the evaluation of competitive examinations.

​The Division Bench of Justice Saumitra Dayal Singh and Justice Swarupama Chaturvedi observed, “The institutional mechanism adopted by the Consortium, involving subject experts and an Oversight Committee, reflects a structured and reasoned approach to finalisation of the answer key. Such determinations, having been arrived at after due academic scrutiny, ought not to be unsettled in the absence of compelling and demonstrable error…In that view of the matter, the interference by the learned Single Judge, though well-intentioned, does not align with the settled parameters governing judicial review in academic matters.”

Senior Advocate Ashok Khare appeared for the Consortium of National Law Universities, while Advocate Nishant Mishra appeared for the Respondent.

Both intra-court appeals arose from a common judgment rendered by the Single Judge in a writ petition instituted by the original petitioner.

Factual Background

The Consortium conducted the entrance examination, which comprised multiple sections. Following the exam, the Consortium withdrew one question and evaluated the candidates on the remaining marks. Although the original petitioner filed objections against the provisional answer key, the Oversight Committee upheld the original answers, and the final key was published without any changes.

The original petitioner challenged this outcome under Article 226 of the Constitution. The Single Judge held that the High Court possessed territorial jurisdiction where the cause of action arose and affirmed the Court's authority to scrutinize answer keys in exceptional cases. Consequently, the Single Judge partly allowed the petition and the Consortium was directed to revise the merit list regarding a specific contested question, though the Court protected admissions already finalized in the initial counselling round.

The Consortium preferred the present appeal, contending that the Court erred by interfering with expert opinions. Conversely, the original petitioner filed a cross-appeal, arguing that the relief should have extended to other erroneous questions.

Contention of the Parties

Consortium submitted that the Single Judge erred in law by interfering with the final answer key, although the objection regarding territorial jurisdiction was not pressed. It was contended that the evaluation followed a rigorous two-tier scrutiny involving subject experts and a formal Oversight Committee, which affirmed the accuracy of the answers after considering all objections. Counsel urged that judicial review in academic evaluations remained extremely narrow, arguing that the Court should not have substituted its own opinion for that of expert bodies. It was further maintained that the direction to recognize multiple correct options was legally unsustainable and unsettled a finalized academic process.

Per contra, the original writ petitioner submitted that the Single Judge erred by failing to grant comprehensive relief despite identifying clear infirmities in the answer key. It was contended that patent errors existed not only in the question addressed by the Court but also in other specified questions, which suffered from mistakes apparent on the face of the record. It was urged that the High Court’s jurisdiction under Article 226 remained available to rectify demonstrably incorrect answers, as judicial review extended to correcting manifest errors to preserve the integrity of the selection process.

Observations of the Court

The Court considered three points, viz. i. The circumstances under which, and the extent to which, Courts could examine the merits of academic decisions rendered by expert bodies; ii. Whether the final answer keys for the disputed questions were correct, or if judicial interference was warranted in respect of any of those questions; and iii. Whether the Single Judge acted within the justified bounds of law, given the limited scope of judicial review in academic matters pertaining to evaluation and answer keys.

Regarding the scope of judicial review in academic matters, the Court said that the scope of judicial review in matters concerning the evaluation of answer scripts in examinations is very limited and guided by well-established principles. It said that the Supreme Court has consistently recognized that issues relating to the correctness of answers and the evaluation standards fall within the domain of concerned academic professionals, who possess the requisite expertise in the subject.

“Having considered view that the scope of interference in academic matters is available yet limited, it becomes necessary to examine the correctness of the reasoning adopted by the Expert Committees and the Oversight Committee in relation to the disputed questions, as well as the basis on which the learned Single Judge has differed from the said expert opinion. For this purpose, the relevant questions, the answers as notified in the final answer key, and the reasons recorded by the Subject Expert Committee as well as the Oversight Committee, as placed on record through the counter affidavit and annexures, are being considered herein below”, it held.

The Court also examined the disputed questions in light of the settled legal principles governing judicial restraint in academic matters. A careful perusal was conducted of the question paper, the final answer key, and the expert opinions placed on record.

“Upon examination of Questions Nos. 6, 9 and 13 of Set-C, we find that the answers accepted as final, is plausible and reasonable interpretation of the questions. Submissions as well as records could not demonstrate that the answers suffer from any patent error or that they are such that no reasonable expert could have arrived at them…In such circumstances, we are of the considered view that no interference is warranted with respect to the answer key pertaining to Questions Nos. 6, 9 and 13 of Set-C”, it said.

The Court said that the answers adopted by the consortium fall within the realm of a reasonable academic interpretation. There is nothing on record to suggest that between the expert committee and the Oversight Committee, one was above the other as per the main consortium documents and both committees comprise experts and are established in due course of time as a matter of practice to ensure accuracy.

Accordingly, the Court set aside the impugned judgment, allowed the appeal filed by the Consortium and dismissed the appeal filed by the original writ petitioner.

Cause Title: Consortium of National Law Universities Through its Convenor v. Avneesh Gupta (Minor) Through His Father and Natural Guardian Shri Atul Gupta and another matter [Neutral Citation: 2026:AHC:106466-DB]

Appearances:

Appellant: Senior Advocate Ashok Khare, Advocates Avneesh Tripathi and Nishant Mishra

Respondents: Advocates Nishant Mishra, Abhinav Gaur and Vibhu Rai

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