The Madhya Pradesh High Court has reaffirmed the principle that candidates must be given a fair opportunity to raise objections before finalizing recruitment answer keys. In a recent order, the Court directed respondents to reconsider the petitioner's objections to an altered answer key, which had cost him selection by a mere 0.34 marks. This judgment underscores the importance of procedural fairness in public recruitment processes.
Background & Facts
The Dispute
The petitioner, Vijay Rathod, participated in the Recruitment Test-2025 for the post of Police Constable conducted by the State of Madhya Pradesh. After the examination, the final answer key was altered without providing any reasons or issuing notice to candidates whose answers were initially marked correct. This unilateral modification resulted in the petitioner missing the selection cutoff by 0.34 marks.
Key Facts
- The recruitment examination for Police Constable was held under Recruitment Test-2025
- The final answer key was modified without notice to affected candidates
- The petitioner discovered the change and attempted to raise objections, but no online link was available for submission
- The petitioner’s representations were not accepted by the authorities
- Due to the modification, the petitioner missed the cutoff by 0.34 marks
Procedural History
- Prior Precedents: The petitioner relied on earlier judgments where similar issues were addressed:
- Arpit Sahu & Ors. vs. The State of Madhya Pradesh & Ors. in W.P. No. 20332/2025 (and connected matters), decided on 10.12.2025 (Jabalpur Bench)
- Neeraj Mishra & Ors. vs. The State of Madhya Pradesh & Ors. in W.P. No. 26416/2024, decided on 10.12.2025
- Jitendra Rajput vs. The State of Madhya Pradesh & Ors. in W.P. No. 26558/2023, decided on 13.12.2025
- Present Petition: The petitioner filed Writ Petition No. 24852 of 2026 before the Indore Bench of the Madhya Pradesh High Court
Relief Sought
The petitioner sought:
- A direction to the respondents to reconsider his objections to the altered answer key
- An opportunity to submit objections as per the procedure followed in earlier cases
- Restoration of his marks based on the original answer key
- Inclusion in the selection list if his objections were upheld
The Legal Issue
The central question was whether modification of a recruitment answer key without notice to affected candidates violates the principles of natural justice, and whether the respondents are obligated to reconsider objections before finalizing the selection process.
Arguments Presented
For the Petitioner
- Relied on the judgments in Arpit Sahu, Neeraj Mishra, and Jitendra Rajput to argue that unilateral modification of the answer key without notice is procedurally unfair
- Contended that the petitioner was denied an opportunity to raise objections, which is a violation of natural justice
- Submitted that the petitioner missed selection by a marginal 0.34 marks, which could have been rectified if objections were considered
For the Respondent/State
- Argued that the modification in the answer key was based on expert opinion, and thus, no interference was warranted
- Contended that the process followed was in accordance with administrative discretion
The Court's Analysis
The Court examined the precedents cited by the petitioner and observed that similar issues had been addressed in earlier cases. Specifically, the Court relied on its earlier directions in Arpit Sahu and Neeraj Mishra, where it had emphasized the need for fair consideration of objections before finalizing recruitment results.
"Thus, petition is disposed of with the direction to respondent No.3 to consider the objections submitted by the petitioners and do the modification in the model answer key (if objections are found correct) and grant appropriate marks accordingly, thereafter, prepare the revised merit list and communicate the same to the respondent No.2. As the order is being passed in the absence of selectees, this is also directed to respondent No.3 to issue notice to all the selectees to submit their objections before modification in the model answer key and then prepare revised merit list on the basis of modified answer key. The said list then be forwarded to respondent No.1 and 2 for preparation of fresh selection list. The aforesaid exercise be done within 15 days from today till then the respondent No.1 and 2 are directed not to proceed with the appointment process."
"In view of the observation made by the Full Bench, the matter deserves to be relegated to the expert body, as the cases of the petitioners have not been considered because of the expiry of the link after taking one objection. Thus, petitions are disposed of with direction to the petitioners to re-submit the objection. For that purpose, the entire memo of petition be placed before the respondents within seven days from today for expert opinion. In turn, the respondents are directed that the objection raised by the petitioners shall be decided within a further period of one month from the date of receipt of the objection."
The Court reiterated that if any answers were found incorrect by the experts, the respondents should not take action against the persons who prepared the model answer key, ensuring an independent and fair decision-making process.
The Verdict
The Court disposed of the writ petition with the following directions:
- Respondents No. 3 and 4 were directed to allow the petitioner to submit his objections against the change in the final answer key
- The respondents were to take a decision on the objections as per the directions given in Arpit Sahu and Neeraj Mishra
- The Court clarified that it had not opined on the merits of the case, leaving the final decision to the expert body
- The petition was disposed of without any further monetary or specific relief, but with a procedural direction for reconsideration
What This Means For Similar Cases
Natural Justice in Recruitment Processes
This judgment reinforces that administrative authorities cannot unilaterally modify recruitment answer keys without providing affected candidates an opportunity to raise objections. Practitioners should:
- Argue for strict adherence to procedural fairness in recruitment processes
- Highlight that even marginal discrepancies (e.g., 0.34 marks) can have significant consequences for candidates
- Rely on precedents like Arpit Sahu and Neeraj Mishra to establish obligations of the recruiting authority
Expert Opinion Must Be Independent and Fair
- The Court emphasized that expert bodies must independently evaluate objections without bias
- Authorities should not penalize those who prepared the original answer key, ensuring objective decision-making
- Timelines for compliance (e.g., 15 days, 1 month) should be strictly followed to avoid delays in recruitment
Remedies for Affected Candidates
- Candidates who are denied an opportunity to raise objections can seek judicial intervention under Article 226 of the Constitution
- Courts are likely to direct reconsideration of objections rather than grant substantive relief upfront
- Practitioners should ensure that all procedural steps (e.g., notice to selectees, expert evaluation) are followed before finalizing selections
