The Madras High Court recently dismissed a petition filed by a disabled candidate who failed to sign his answer sheet while appearing for the Combined Civil Services Examination-IV (Group-IV Services) conducted by the Tamil Nadu Public Service Commission (TNPSC). The petitioner, Mohammed Ibrahim, sought relief from the court, requesting the evaluation of his answer sheet despite not having signed it.
Court’s Observations on Examination Rules
Justice C.V. Karthikeyan, who presided over the case, emphasized that the instructions provided by TNPSC were clear and mandatory. The court noted that allowing an exception in this case would alter the rules of the examination process, which must be applied uniformly to all candidates.
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"The submissions made by the learned counsel across the bar is appreciated, but acceding to the same would be far exceeding the scope of examination and changing the rules of the game. The instructions very specifically stipulate various options, instead of affixing the signature to at least affix either one thumb impressions, if both are not possible," the court stated.
The court also remarked that changing the examination rules for one candidate could set a precedent for other candidates who might have committed similar errors, leading to legal complications and inconsistent evaluation standards.
Background of the Case
Mohammed Ibrahim, who suffers from a 60% locomotive disability, appeared for the Group-IV Services exam conducted by TNPSC. He was allotted a scribe and provided a separate room for the examination. Upon completion, his scribe submitted the answer sheet to the invigilator. However, due to Ibrahim's failure to sign the answer sheet, his response sheet was not evaluated, and his results were not declared.
His counsel argued that the answer sheet should still be considered by verifying its authenticity through the registration number. The request was made on the basis that Ibrahim faced physical limitations due to his disability, which restricted his ability to affix a signature.
TNPSC’s Response and Court’s Ruling
TNPSC, through a counter-affidavit, asserted that the examination instructions were explicit and provided alternatives for candidates who could not sign. According to Clause 4.10 of the guidelines, candidates unable to use both hands and permitted to use a scribe could leave the signature and thumb impression column blank. However, Ibrahim had only mentioned that his right hand was paralyzed and did not specify that he was unable to use both hands.
The court highlighted that adherence to these instructions was crucial, as exceptions could lead to unnecessary complications. Citing the Supreme Court ruling in Ran Vijay Singh & Others v. State of Uttar Pradesh & Others, the court emphasized the importance of following examination rules strictly.
"Sympathy or compassion does not play any role in the matter of directing or not directing re-evaluation of an answer sheet. If an error is committed by the examination authority, the complete body of candidates suffers. The entire examination process does not deserve to be derailed only because some candidates are disappointed or dissatisfied," the Supreme Court had ruled.
Additionally, the High Court referred to Civil Appeal No. 6669 of 2019, where the Supreme Court reiterated that examination rules are mandatory and cannot be altered by judicial intervention.
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"The instructions issued by the Commission are mandatory, having the force of law, and they have to be strictly complied with. The High Court in exercise of powers under Article 226 of the Constitution cannot modify or relax the instructions issued by the Commission."
After considering all aspects, the High Court ruled that since the petitioner had failed to affix his signature or thumb impression, his answer sheet could not be evaluated. The court dismissed the petition, stating that judicial discretion could not be used to modify established rules of the exam
Counsel for the Petitioner: Mr. R. Sivakumar
Counsel for the Respondents: Ms. G. Hema, Standing Counsel
Case Title: Mohammed Ibrahim v. The Secretary, TNPSC and Another
Case No: W.P.No.33691 of 2024
