One Mark, Ten Years Later: Supreme Court Reverses High Court on a Disputed Mughal-History Answer Key

Case at a glance: The Supreme Court has set aside an Allahabad High Court review order that awarded a Village Development Officer candidate one extra mark on a question about Mughal-era books and directed his appointment. It held that the Commission's answer was neither patently wrong nor arbitrary, and that courts must read an exam question “as it stands and not what it ought to have been.”

The Commission advertised 3,133 Village Development Officer posts on 18 January 2016 and held the written test on 5 June 2016. Question 68 asked which pair was incorrect: Baburnama–Babur, Shahjahannama–Mohd. Taahir, Humayunnama–Humayun and Tuzuk-e-Jahangiri–Jahangir. The Commission keyed option (B). The respondent chose (C), arguing that the Humayunnama was written by Gulbadan Begum, not Humayun.

His writ petition was dismissed on grounds of laches and the intra-court appeal failed on 20 January 2021. On review, however, the High Court on 20 March 2026 relied on an expert report dated 10 August 2020, held that he was entitled to one mark, and directed the Commission to declare his result and the State to appoint him.

The Key Question Before the Court

Was the High Court justified in interfering with the Commission's decision to treat option ‘B’ as the only correct answer?

Limits of Judicial Review Over Answer Keys

Applying Ran Vijay Singh v. State of U.P., (2017) 12 SC CK 0001 and U.P. PSC v. Rahul Singh, (2018) 06 SC CK 0003, the Court restated that the answer key is presumed correct, the onus lies on the candidate, interference is warranted only where the mistake is so glaring that “no inferential process or reasoning is required” to see it, the benefit of doubt goes to the examining body, and courts must be strict about delay.

The question did not specify the basis of pairing. Pairing a book with its subject is a commonsense approach, on which option (B) is the only mismatch, and “such an approach cannot by any stretch of imagination be considered arbitrary or irrational.” The expert report did not say that option (B) was wrong; it only offered a possible answer if authorship was read into the question. The candidate had read into the question something it did not say, and the High Court exceeded its jurisdiction, particularly in review.

What the Court Actually Held

• Neither the question nor the Commission's option (B) was incorrect.
• Courts must assess a question as it stands, not as it ought to have been framed.
• The High Court overstepped its jurisdiction, especially in exercising review.
• The appeal was allowed, the review order set aside and the writ petition dismissed.

Why This Judgment Matters

• It reaffirms the narrow window for challenging answer keys in recruitment exams.
• It cautions against using review to reopen concluded matters on fresh expert opinion.
• It protects the finality of selection processes years after results.

What Should Advocates Take Away From the Judgment?

For Candidates' Counsel

• Show that the key is demonstrably wrong without inferential reasoning, not merely that another answer is possible.
• Approach the court promptly; delay weighs heavily.

For Recruiting Bodies

• Keep expert reports clear on whether the keyed answer is wrong or only one possible view.
• Defend keys on the question's own wording.

Key Takeaways

Frequently Asked Questions

No. It held only that, on the question as framed, the Commission's option (B) was not incorrect.

Because it did not say option (B) was wrong; it only supported (C) if authorship was assumed as the basis of pairing.

It falls with the review order, and his original writ petition stands dismissed.

Conclusion