The Manipur High Court has upheld the right of candidates appearing in the Manipur Civil Services Combined Competitive Examination (MCSCCE), 2016 (2022), to inspect their evaluated answer scripts, dismissing three writ petitions filed by the Manipur Public Service Commission (MPSC) against the Manipur Information Commission (MIC).
Justice A. Guneshwar Sharma ruled that although MPSC policies dated May 4 and October 28, 2020 prohibit the supply of certified copies of evaluated descriptive answer scripts under normal circumstances, the policies do not prevent candidates from inspecting their own evaluated scripts.
The court clarified that it was not examining the validity of the MPSC policies, as that issue is already pending before a Division Bench.
The petitions arose from a common order of the MIC directing the MPSC’s State Public Information Officer to allow three RTI applicants to inspect their evaluated answer scripts after their requests for certified copies had been rejected.
Appearing for the MPSC, senior advocate M. Rarry, assisted by M. Nikita, argued that the Commission’s policy was framed in accordance with Supreme Court rulings, including Union Public Service Commission v. Angesh Kumar and Prashant Ramesh Chakkarwar v. UPSC. The judgments, he submitted, caution against disclosure of evaluated answer books to protect the integrity of competitive examinations.
Counsel for the RTI applicants, senior advocate S. Rupachandra, assisted by Royal Salam, argued that the MPSC policy prohibits furnishing certified copies but does not prohibit inspection of answer scripts. He also submitted that the applicants were satisfied with being allowed to inspect their own evaluated scripts. Advocate K. Kishan adopted the submissions on behalf of some applicants.
Representing the Manipur Information Commission, K. Roshan supported the MIC order, submitting that inspection would promote transparency without compromising the confidentiality of the evaluation process.
The High Court held that inspection of an evaluated answer script is legally distinct from providing a certified copy. It also found that the Supreme Court’s decision in Angesh Kumar, which dealt with disclosure of raw marks and evaluation methodology, was distinguishable from the present case.
Instead, the court relied on the Supreme Court’s ruling in Mradul Mishra v. Chairman, U.P. Public Service Commission, which held that allowing candidates to inspect their own answer sheets does not adversely affect public interest or the integrity of the examination system.
The High Court accordingly dismissed the three writ petitions and directed the MPSC to comply with the MIC’s order within 30 days. The parties were directed to bear their own costs.
