Allahabad HC Dismisses Plea For Re-Evaluation By Final Year Law Student Who Got Zero Marks, Quotes Answer And Forwards Answerbook To BCI & Law Commission
The Bench held that examiners cannot be faulted for awarding zero marks to law answers lacking legal comprehension.
Justice Vinod Diwakar, Allahabad High Court
The Allahabad High Court dismissed a writ petition filed by a final-year B.A. LL.B. student seeking re-evaluation of his examination paper in which he was awarded 'zero marks' across all attempted questions. While holding that judicial review in academic evaluation is extremely limited, the Court observed that the poor performance was as much a reflection of the institution's failure to provide adequate teaching and guidance as it was of the student's own shortcomings.
Refusing to interfere with the evaluation, the Court observed that when an examinee's written answers reveal a total absence of legal comprehension or logical reasoning, no fault can be attributed to the examiner for awarding zero marks.
Accordingly, the Bench directed that redacted copies of the student’s question paper and answer book be sent to the Bar Council of India (BCI) and the Law Commission of India to examine institutional deficiencies and formulate necessary legal education reforms.
A Single Judge Bench of Justice Vinod Diwakar observed, "Legal education constitutes the foundation of the justice delivery system. Any substantial decline in academic standards at the institutional level affects not merely the legal profession, but the administration of justice itself... It is not unlikely that, had the student been properly counselled before the examination, had a suitable orientation programme been provided, and had he been adequately taught, supervised and apprised of what is expected of an examinee, the answers in question would not have been written in the manner they were. The deficiency, if any, lies as much in the institution's failure to discharge its responsibility of imparting quality education as in the answers produced by the student".
Advocate Vinay Kumar Dwivedi appeared for the petitioner and Advocate Pratik Chandra appeared for the respondent.
In the matter, Vindhya Vasini Prasad Pandey, a student of the five-year B.A. LL.B. program at Prayag Vidhi Mahavidyalaya, Naini, Prayagraj, an institution affiliated with Prof. Rajendra Singh (Rajju Bhaiya) University.
Having cleared Semesters I through VIII, the petitioner appeared in the B.A. LL.B. IX Semester Examination 2025–26, including the paper "Bio-Diversity Protection Law". Upon declaration of the results on March 18, 2026, the petitioner was awarded zero marks in all attempted questions. Expecting over 50 marks, he obtained a copy of his evaluated answer sheet under the RTI Act, confirmed the zero-mark evaluation, and approached the High Court after his representations to the University yielded no response.
The petitioner filed a writ petition seeking a writ of mandamus for re-examination of his answer sheet and issuance of a revised mark sheet, pointing out that he had qualified for the LL.M. entrance examination and was awaiting counseling. On a previous date of hearing, the High Court directed the respondent-University to produce the original question paper and evaluated answer book.
During the hearing, the Court directed the Standing Counsel to read aloud the petitioner’s answer to Question No. 3-C, which asked candidates to describe national laws in India related to biodiversity conservation.
The Standing Counsel conceded that he was unable to comprehend the purport of the answer, which contained nonsensical phrases such as "maternity of grudges", "trustee of God", "felicititation of discovery", and referred to non-existent statutes like the "Biodiversity Origin and Regulation Act 1996". The Bench independently reviewed the answer book and concluded that the candidate displayed no legal understanding of the subject whatsoever.
Consequentially, the Court dismissed the writ petition, finding no arbitrariness or procedural error under Article 226 of the Constitution of India.
Cause Title: Vindhya Vasini Prasad Pandey v. State of U.P. & 3 Ors. (Neutral Citation: 2026:AHC:146040)
Appearances:
Petitioner: Vinay Kumar Dwivedi and Vinod Kumar Ojha, Advocates.
Respondents: C.S.C. and Pratik Chandra, Advocates.