Supreme Court Restores UPSSSC Answer Key, Holds Option B Correct for Disputed History Question

A Division Bench of Justices Manoj Misra and Vijay Bishnoi held that courts cannot read an unstated parameter into an examination question and second-guess the examining body.

The Supreme Court on 9 September 2026 set aside an Allahabad High Court order that had, in review jurisdiction, awarded one mark to a candidate who chose Option C — Humayunnama/Humayun — as the incorrect pair in a multiple-choice question in the 2016 Uttar Pradesh Village Development Officer examination. The Court held that the Uttar Pradesh Subordinate Service Selection Commission had committed no glaring or patent error in selecting Option B as the correct answer, and that the High Court had overstepped its jurisdiction. The judgment restores the Commission's answer key and dismisses the underlying writ petition, settling the career dispute of a candidate who had invoked expert opinion to challenge the result more than three years after it was declared.

The 2016 Examination and How the Dispute Arose

The Commission published an advertisement on 18 January 2016 inviting applications for 3,133 posts of Village Development Officer. A written test of objective-type questions was held on 5 June 2016. A provisional answer key appeared on 9 June 2016, and after objections a revised key was published on 30 June 2016. The result based on the revised key was declared on 18 July 2018. Supplementary result followed on 26 June 2020 after directions in certain other writ petitions.

Question 68 in the General Knowledge section asked candidates to identify the incorrect pair from four book-and-name combinations: Baburnama–Babur, Shahjahannama–Mohammad Tahir, Humayunnama–Humayun, and Tuzuk-e-Jahangiri–Jahangir. The Commission's revised answer key gave Option B (Shahjahannama–Mohammad Tahir) as the correct answer. The respondent, Ashok Yadav, had chosen Option C (Humayunnama–Humayun), on the ground that Humayunnama was not written by Humayun but by Gulbadan Begum.

Yadav filed Writ A No. 10221 of 2019 before a Single Judge seeking one mark for his answer. The Single Judge dismissed the petition on laches, also citing this Court's caution in U.P. Public Service Commission v. Rahul Singh (2018) 7 SCC 254 that constitutional courts must be reluctant to entertain challenges to key answers. An intra-court appeal before a Division Bench was dismissed on 20 January 2021 by relying on decisions of this Court. Yadav then filed a review petition.

The High Court's Review Order

The High Court allowed the review petition by its order dated 20 March 2026. It held that an expert report dated 10 August 2020 — obtained from two academics at DSMNR University Lucknow and B.B. Ambedkar University Lucknow — had not been placed before either the Single Judge or the Division Bench earlier, even though it was relevant. Acting on that report, the High Court concluded that Option C was the correct answer, set aside the Single Judge's order, and directed the Commission to declare Yadav's result and make a recommendation. The State Government was directed to issue an appointment.

The expert report itself stated two possibilities: if matching is by authorship, Option C is correct because Humayunnama was written by Gulbadan Begum and not Humayun; if matching is by subject — the person about whom the book is written — Option B is correct because Shahjahannama is not about Mohammad Tahir but about Shahjahan. The report did not declare Option B to be wrong.

Competing Arguments Before the Supreme Court

The Commission, represented by Senior Advocate P.S. Patwalia, argued that the expert report was equivocal. The question contained no statement that pairing had to be done by authorship. Without any such parameter, a commonsense subject-wise approach — the book and the person it is about — points to Option B as the only mismatched pair. Phonetically too, Option B is the only combination that does not correspond. The writ petition was filed long after the result, and the Commission's decision was neither arbitrary nor perverse.

Senior Advocate Sudhir Kumar Saxena, for the respondents, submitted that Question 68 appeared in the General Knowledge section, and general knowledge about who authored a book is precisely what that section tests. All other options pair a book with its author, so only Option C stands out on that reading. In the alternative, if the question admitted both subject-wise and authorship-based pairing, there were two correct answers — B and C — and marks should be awarded for both. Reliance was placed on Siddhi Sandeep Ladda v. Consortium of National Law Universities [2025] 7 S.C.R. 55 for the proposition that courts are not entirely powerless when examination authorities act in ways that damage the career prospects of large numbers of students.

The Court's Analysis: No Glaring Mistake, No Occasion for Review

The Court began by restating the controlling legal position from Ran Vijay Singh v. State of U.P. (2018) 2 SCC 357 and U.P. Public Service Commission v. Rahul Singh. Those decisions establish that a challenge to a key answer can be entertained only where the error is so glaring and apparent that no inferential process or reasoning is needed to demonstrate it. There is a presumption of correctness in favour of the key answer. In case of doubt, the benefit goes to the examining body, not the candidate. Courts have no expertise in academic matters and should exercise great restraint.

Applying those principles, the Court found that Question 68 did not specify any parameter for identifying the incorrect pair. Absent a stated principle, a commonsense approach — matching each book with the person it is about — was what the Commission adopted. That approach cannot be called arbitrary or irrational. On that approach, Option B is the pair that does not match: Shahjahannama is not about Mohammad Tahir. Option B is also the only mismatch if one reads the pairs phonetically.

The Court observed that the candidate's difficulty arose because he applied inferential logic, reading into the question an unstated authorship parameter. Yadav likely would not have selected Option C had he not known the historical fact that Gulbadan Begum, not Humayun, wrote Humayunnama. The Court acknowledged the apparent unfairness: “one may feel that the writ petitioner is being punished for having knowledge about a historical fact.” But it held that this is not the test. The test is whether the mistake is so glaring that no inferential process is needed to find it. On that test, the Commission's choice fails no standard.

The Court also rejected the argument that because the question appeared in the General Knowledge section, authorship must have been the intended parameter. A question is to be understood as it stands, not as it might have been drafted. Reading a sectional context into the question is itself an inferential exercise of the kind that judicial review of answer keys does not permit.

Why the Expert Report Did Not Help the Respondent

The High Court had treated the expert report of 10 August 2020 as the basis for awarding marks for Option C. The Supreme Court pointed out that the report is not categorical. It presents two alternative readings of the question and gives a different correct answer for each. Critically, it does not say that Option B is wrong. It only says that if matching by authorship is the logic, Option C is the answer. The report in fact confirms that subject-wise matching leads to Option B.

The Court held that the High Court, while acting on the report, overlooked that the report had only indicated a possible answer if the question were perceived as relating to authorship. The report did not fault the question. Authorship was not the underlying principle for identifying the incorrect pair, and therefore neither the question nor its answer was patently incorrect. There was no occasion for the High Court to interfere, particularly in the exercise of review jurisdiction, which is narrower still.

The Court also reiterated a broader caution drawn from Ran Vijay Singh: excessive judicial interference with examination results places authorities under scrutiny rather than candidates, creates prolonged uncertainty for all participants, and is contrary to public interest. The examination in this case was held in 2016. The dispute about one question had persisted through a writ petition, an intra-court appeal, a review petition, and now a Supreme Court appeal — a span of a decade.

Outcome

The Court allowed the appeal, set aside the High Court's review order dated 20 March 2026, and dismissed Writ A No. 10221 of 2019 filed by the respondent before the High Court. All pending applications were disposed of. The Commission's selection of Option B as the correct answer stands.