Dismissed¶57

D.Amrish v. the State of Tamilnadu

Madras HC18 Jun 2025WP/18976/2025

Case brief

AI extract

What is this about?

Madras High Court; writ petition under Article 226; mandamus; answer key re-evaluation; independent expert committee; Medical Services Recruitment Board (MRB); Assistant Surgeon (Dental); Notification No.05/MRB/2025 dated 25.02.2025; provisional answer key objections to Q.Nos. 1, 32, 35, 47, 72, 76; result published 14.05.2025; final answer key after results; 1,448 objections from 558 candidates; locus standi; non-communication of Expert Committee findings; judicial review over answer key; malafide; domain of subject experts; Dr. J. Dharani v. State of Tamil Nadu W.P. No. 6634 of 2025 (26.02.2025); D.Amrish; C. Kumarappan J.; dismissed, no costs; connected W.M.P. No. 21261 of 2025 closed.

What did the court decide?

Answer keys fall within the domain of subject experts, and the findings of the Expert Committee need not be communicated to the candidate.

D.Amrish Vs the State of Tamilnadu — Writ and Judicial Review | Madras HC (2025)

What the court decided

AI extract

Outcome

Dismissed

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Issue for consideration

Whether a writ of mandamus should issue directing the respondents to conduct a comprehensive re-evaluation of the entire answer key through a competent and independent expert committee, taking into account the petitioner's and similarly placed candidates' objections, and to grant appropriate relief including revision of marks. +2 more

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Ratio / Principle

Answer keys fall within the domain of subject experts, and the findings of the Expert Committee need not be communicated to the candidate.

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Key takeaways

Unless the petitioner demonstrates malafide on the part of the experts, the power of judicial review cannot be exercised over the answer key, as it lies within the expert domain (adopting the ratio in Dr. J. Dharani v. The State of Tamil Nadu, W.P. No. 6634 of 2025).ratio¶56

Detailed headnote1 paragraphs

High Court of Judicature at Madras (C. Kumarappan, J.), 18.06.2025 - W.P.No.18976 of 2025: A dental surgeon candidate in the Medical Services Recruitment Board's recruitment to the post of Assistant Surgeon (Dental) (Notification No.05/MRB/2025 dated 25.02.2025), who had objected to Question Nos. 1, 32, 35, 47, 72 and 76 of the provisional answer key, sought mandamus for a comprehensive re-evaluation of the entire answer key by an independent expert committee and revision of marks, the result having been published on 14.05.2025 without release of the final answer key or reply to his objections. HELD: (i) answer keys fall within the domain of subject experts and the findings of the Expert Committee need not be communicated to the candidate; (ii) absent demonstrated malafide on the part of the experts, judicial review cannot be exercised over the answer key, it lying within the expert domain, following the ratio in Dr. J. Dharani v. The State of Tamil Nadu, W.P. No. 6634 of 2025 (order dated 26.02.2025). Of the petitioner's objections, that to Question No.32 had been accepted and the relevant papers re-evaluated. Writ petition dismissed with no costs; connected W.M.P. No. 21261 of 2025 closed.

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W.P.No.18976 of 2025

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED : 18.06.2025

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CORAM

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THE HONOURABLE Mr.JUSTICE C.KUMARAPPAN

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W.P.No.18976 of 2025 and

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W.M.P.No.21261 of 2025

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D.Amrish ... Petitioner

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Vs.

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1.The State of Tamil Nadu, Rep by its Secretary, Health and Family Department, Fort St.George, Chennai – 9.

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2.The Director of Medical & Rural Health Services, D.M.S.Buildings, 359, Anna Salai, Teynampet, Chennai – 600 006.

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3.The Medical Services Recruitment Board, Rep by its Member Secretary, 7^th Floor, D.M.S.Buildings, 359, Anna Salai, Teynampet, Chennai – 600 006.

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... Respondents

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Writ Petition filed under Article 226 of the Constitution of India praying to issue a Writ of Mandamus, directing the respondents to conduct a

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https://www.mhc.tn.gov.in/judis

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W.P.No.18976 of 2025

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comprehensive re-evaluation of the entire answer key through a competent and independent expert committee by taking into due consideration the objections raised by the petitioner and other similarly placed candidates and grant appropriate relief including revision of marks based on such reevaluation.

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For Petitioner : Mr.P.Abishek for M/s.Pon Law Associates For Respondents : Mr.K.Tippu Sultan Government Advocate for R1 and R2

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Mr.L.Murugavelu Standing Counsel for R3

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O R D E R

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The instant writ petition has been filed with a prayer for issuing a

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mandamus, to direct the respondents to conduct a comprehensive re-evaluation of the entire answer key through a competent and independent expert committee by taking into due consideration the objections raised by the petitioner and other similarly placed candidates and grant appropriate relief including revision of marks based on such re-evaluation.

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https://www.mhc.tn.gov.in/judis

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W.P.No.18976 of 2025

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The learned counsel for the petitioner would submit that he is a qualified dental surgeon holding a Bachelor’s degree from SRM Dental College, Ramapuram. It is further submitted that, pursuant to the Notification issued by Respondent No.3 vide Notification No.05/MRB/2025 dated 25.02.2025, calling for applications for the post of Assistant Surgeon (Dental), the petitioner appeared for the written examination.

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It is the further submission of the petitioner, that there was an error in the provisional answer key, for which, the petitioner has raised objections to question Nos.1, 32, 35, 47, 72, and 76. However, without releasing the final answer key, the respondents published the result on 14.05.2025, without any communication or reply to the petitioner regarding his objections. Hence, the petitioner prays for the entire answer key to be reevaluated by a competent and expert body.

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Per contra, the learned Standing Counsel appearing for the 3^rd respondent would submit that after the release of the provisional answer key, they received 1,448 objections from 558 candidates. All objections were placed before the Expert Committee, and based on their review, the answers

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https://www.mhc.tn.gov.in/judis

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W.P.No.18976 of 2025

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were modified and justified by the subject experts. It is further submitted that, in respect of the objections raised by the petitioner on 5 questions, the objection for question No.32 was taken into consideration and the relevant papers were appropriately evaluated. He further submits that the final answer key would be released only after the publication of the result. Therefore, the petitioner has no locus standi to file the present writ petition.

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Heard the learned counsel for the petitioner and the learned Government Advocate appearing for the first and second respondents and the learned Standing Counsel appearing for the third respondent and perused the materials available on records.

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The substance of the petitioner’s contention is that although he raised objections to the provisional answer key, he was not given any notice or communication regarding his objections before the result was published. It is a well-settled principle of law, that answer keys fall within the domain of subject experts. The findings of the Expert Committee meed not be communicated to the petitioner.

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https://www.mhc.tn.gov.in/judis

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W.P.No.18976 of 2025

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In this connection, the learned counsel for the petitioner relies upon

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the judgment of the learned Single Judge of this Court in W.P.No.6634 of 2025 in the case of Dr.J.Dharani Vs. The State of Tamil Nadu vide order dated 26.02.2025. The relevant Paragraphs from the said order, reads as

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under:-

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“17.It is thus seen that not only were the questions examined but also the answers were examined to determine the correct choice out of the four possible choices for that particular question. The key answer is given and then in a brief paragraph, the justification is given as to why that particular key answer is correct. It was not just a personal opinion of the expert to that particular key answer, but the reference material or material from which the expert was able to get the correct key answer was also given.

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18.These are all part of records. Unless the Court were to impute malafide on the part of the expert who set the question paper, that a particular question was set to favour a particular candidate and the Court were to further impute malafide on the part of the expert who evaluated the question and also identified the correct answer and more importantly, if the Court were to doubt whether the particular study material on the basis of which the answer was cross verified does not relate to the issue at all, the Court should not embark on a journey to question the correctness of the opinion of the expert and the correctness of the fact stated in the reference book and the correctness of the question viz-a-viz the correctness/choice.

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19.The learned Additional Advocate General had produced all the relevant details with respect to each one of the question put forth during the course of arguments and I must respect the expert's opinion that atleast with respect to question

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W.P.No.18976 of 2025

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Nos.20, 64, 70, 83 and 98 the key answers as given by them are correct. That justification is further reinforced by the source material on the basis of which such justification had been given.

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20.The learned counsel for the petitioner placed reliance on further reference materials. It would be extremely dicey for this Court to contradict two separate materials. As pointed out by the learned Additional Advocate General, it is not a question of choosing a similar answer or a probably correct answer but the correct answer. This also indicates choosing the correct reference material. There are books on medicine and theories on medicine but, not at all books could be termed as written by experts. It is the specific book in which the correct answer is given with clarity, which could be relied on by the expert and it had apparently been relied on in this case also.

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21.I hold that the challenge to these questions should necessarily fail as it is beyond the scope of judicial review to examine the correctness or otherwise of the key answers, even if it is to be taken that the answers as projected by the petitioners are also be probably correct. As stated by the Hon'ble Supreme Court, the Courts should leen in favour of the opinion given by the expert who had considerable time, material and had access to various reference books before the correct answer was chosen. The Court has also satisfied itself that for each one of the questions necessary expert opinion had been obtained and necessary reference books had also been examined.

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22.With the above reasonings, this Writ Petition stands dismissed. No costs. Consequently, connected Writ Miscellaneous Petition is closed.”

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https://www.mhc.tn.gov.in/judis

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W.P.No.18976 of 2025

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As per the above ratio, unless the petitioner demonstrate malafide on

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the part of the experts, the power of judicial review could not be exercised over the answer key, as it lies within the expert domain.

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In such view of the matter, this Court finds no merits in this Writ Petition. Accordingly, this Writ Petition is dismissed. No costs. Consequently, connected Writ Miscellaneous Petition is closed.

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18.06.2025

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jas

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Index : Yes/No Speaking order /Non Speaking Order Neutral Citation : Yes/No

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https://www.mhc.tn.gov.in/judis

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