Academic Institutions Have Autonomy To Regulate Evaluation Processes: Karnataka HC Dismisses Plea Challenging State Law University's Valuation System
The Karnataka High Court dismissed the plea of a law student enrolled at the Rajiv Gandhi College of Law seeking fresh evaluation of his results after noticing that the University had already granted him a chance of re-assessment.
The Court held that the Single Judge's decision of dismissing his plea for reconsideration of the University’s valuation system was in accordance with the legal framework that grants academic institutions the autonomy to regulate their examination and evaluation processes.
The appellant-a law student, approached the High Court, with an intra-court appeal filed under Section 4 of the Karnataka High Court Act, 1961 for fresh evaluation of the answer scripts and to declare the results.
The Division Bench comprising Chief Justice N.V. Anjaria & Justice K.V. Aravind said, “In this case, the University adhered to its prescribed revaluation and challenge valuation procedures.”
The Appellant A.J. James appeared as Party-In-Person while Advocate R. Girish Kumar represented the Respondents.
The appellant joined a three year LL.B course at Rajiv Gandhi College of Law, Bengaluru and was admitted to academic year 2016. It was the appellant’s case that he failed in certain subjects and applied for revaluation of the answer scripts. Upon revaluation, marks in certain subjects improved upward and downward as well. It was his case that the valuation standards adopted by the University are not up to the mark. It was pleaded that the appellant is confident of securing the requisite marks to possess a Law Degree. Hence, he had not taken up any further examination. He had approached the High Court for fresh evaluation of the answer scripts.
The University, on the other hand, contended that the benefit of revaluation/challenge valuation is provided and the benefit as assessed is extended to the appellant. The Single Judge dismissed the writ petition holding that the direction to revaluation beyond the regulations cannot be directed. It further held that the regulations have been framed by the experts in the field in the interest of students and the colleges/universities, which the Court cannot step in to substitute the view.
It was the appellant's case that the faculties entrusted with the task of evaluation of answer scripts are not qualified and the medium of education of the evaluators also matters for fair, qualitative and quantitative evaluation of answer scripts.
At the outset, the Bench noted that the University operates under its established ordinances, rules, and regulations, which govern the entire process of conducting examinations, evaluating answer scripts, and announcing results. The revaluation and challenge valuation process, as conducted by the University, has already provided a fair opportunity for the appellant to have his marks reassessed.
Since the University's regulations and procedures for revaluation were followed in this case, and considering the changes in the appellant's marks were within the scope of the University's established process, the Bench did not find sufficient grounds to question or revise the entire valuation system based solely on the results of the appellant's individual revaluation requests.
“In the absence of specific provisions in the University's rules and regulations that would permit the revaluation of the appellant's answer scripts beyond the established revaluation and challenge valuation process, learned Single Judge's rejection of the appellant's prayer for revaluation cannot be held incorrect”, the Bench said while also adding, “Learned Single Judge's decision is in accordance with the legal framework that grants academic institutions the autonomy to regulate their examination and evaluation processes.”
Finding no infinity in the order of the Single Judge and dismissing the appeal, the Bench said, “Therefore, judicial intervention is not warranted, as the appellant's request for further revaluation is not supported by the University's regulations or by any exceptional circumstances that would justify such intervention.”
Cause Tittle: Sri A.J. James v. Karnataka State Law University [Case No. WRIT APPEAL No.257 OF 2024 (EDN-RES)]
Appearance:
Petitioner: Party-in-person Sri A.J. James
Respondent: Advocate R. Girish Kumar
