The Delhi High Court has dismissed a petition filed by several civil services aspirants challenging the Civil Services Preliminary Examination 2023, particularly the CSAT (Paper-II). The court upheld the Central Administrative Tribunal’s (CAT) order and ruled that courts cannot interfere in academic matters unless clear illegality or arbitrariness is proven.
Background of the Case
The petitioners, unsuccessful candidates in the Civil Services Preliminary Examination 2023, approached the court claiming that nearly 11 questions in CSAT Paper-II were beyond the prescribed syllabus. According to them, the examination rules limited the syllabus to Class X-level numerical and data interpretation skills.
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The Civil Services Examination is conducted annually by the Union Public Service Commission (UPSC) for recruitment to elite government services. The preliminary examination took place on May 28, 2023, with results announced on June 12, 2023. The final results of the entire selection process were declared on April 16, 2024.
After failing to clear the preliminary stage, the petitioners submitted objections through UPSC’s grievance portal and later approached the Supreme Court. The apex court allowed them to move the High Court. Their earlier petition was transferred to CAT, which dismissed their plea, leading to the present challenge.
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Petitioners’ Arguments
The petitioners contended that several questions in CSAT Paper-II were taken from Class XI and XII-level NCERT curriculum, violating examination rules. They argued that such deviation created an uneven playing field and compromised the fairness of the selection process.
They also claimed that CAT failed to independently examine the disputed questions. According to them, once the examination deviated from the syllabus, the entire selection process should be reconsidered, including revising the merit list or granting compensatory attempts or age relaxation.
UPSC’s Stand
UPSC strongly opposed the petition, stating that the questions were prepared by subject experts strictly in accordance with the prescribed syllabus. The Commission informed the court that an online objection portal was opened immediately after the exam and all representations were reviewed by a separate expert panel.
The expert committee concluded that all questions were within the syllabus and mathematical questions remained confined to the Class X level. UPSC further argued that identical challenges had already been rejected by the High Court in previous cases.
It also pointed out that the petitioners failed to include successful candidates as parties, even though the relief sought would directly affect their appointments.
Court’s Observations
The bench emphasised the limited scope of judicial review in academic and examination matters. The court observed that it cannot function as an appellate authority over examining bodies or substitute expert opinions.
“The scope of judicial review in matters relating to competitive examinations is extremely limited,” the bench observed, adding that interference is warranted only if the process is affected by mala fide intent, arbitrariness, or patent illegality.
The court relied on multiple Supreme Court precedents which stress that academic decisions, including question paper setting and evaluation, fall within the exclusive domain of subject experts.
The judges also noted that the expert committee examined the objections and clearly concluded that all disputed questions were within the syllabus. The committee further found that the questions were meant to test analytical ability expected from civil services aspirants.
The court stated, “Once the Committee of Experts has opined that the questions were within the syllabus, the very basis of compensatory or corrective reliefs does not survive.”
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Issue of Necessary Parties
Another key concern highlighted by the court was the failure of the petitioners to include successful candidates as respondents. The bench observed that granting relief such as revising merit lists or conducting fresh examinations would directly impact candidates who had already been selected and appointed.
The court reiterated that no adverse order affecting someone’s rights can be passed without giving them an opportunity to be heard.
Completion of Selection Process
The court also noted that the Civil Services Examination 2023 process had already concluded, and subsequent examinations for 2024 and 2025 had been conducted. The bench remarked that courts generally do not grant reliefs that have become impractical or infructuous.
It further rejected the petitioners’ request for additional attempts or age relaxation, holding that examination rules are statutory and policy matters cannot be altered through judicial review.
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Court’s Decision
Finding no error in CAT’s order and relying on the expert committee’s report, the Delhi High Court dismissed the petition. The court also disposed of all pending applications and returned sealed documents submitted by UPSC.
Case Title: Hanumant Lal Patel & Ors. v. Union of India & Ors.
Case No.: W.P.(C) 4354/2025
Decision Date: February 03, 2026
