A) ABSTRACT / HEADNOTE

The case examines whether the National Eligibility-cum-Entrance Test (NEET) (UG) 2024 was compromised due to systemic issues, including allegations of a question paper leak, and if the process should be scrapped and re-examined. The Supreme Court analyzed the extent of the malpractice, whether it impacted the examination system systemically, and assessed if segregation of tainted and untainted candidates was feasible. The Court concluded that the breaches were isolated incidents, identifiable, and did not affect the entire examination’s sanctity. Thus, a re-test was deemed unnecessary. Recommendations for improving the examination’s security and fairness were outlined.

Keywords: Education, NEET (UG) 2024, National Testing Agency (NTA), Examination Integrity, Systemic Deficiencies

B) CASE DETAILS

i) Judgment Cause Title:
Vanshika Yadav v. Union of India & Ors.

ii) Case Number:
Writ Petition (Civil) No. 335 of 2024

iii) Judgment Date:
02 August 2024

iv) Court:
Supreme Court of India

v) Quorum:
Dr. Dhananjaya Y. Chandrachud, CJI; J.B. Pardiwala, J.; Manoj Misra, J.

vi) Author:
Dr. Dhananjaya Y. Chandrachud, CJI

vii) Citation:
[2024] 8 S.C.R. 45 : 2024 INSC 568

viii) Legal Provisions Involved:

• Article 32 of the Constitution of India
• Principles of Natural Justice

ix) Judgments overruled by the Case (if any):
None explicitly stated.

x) Case is related to which law subjects:
Education Law, Administrative Law, Examination Integrity

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The case arises from a series of petitions challenging the validity of the NEET (UG) 2024 conducted by the National Testing Agency (NTA). Allegations of question paper leaks, irregularities in transportation, and discrepancies in marking and results led to calls for a re-exam. The petitioners argued systemic deficiencies in the examination’s administration, citing specific centers such as Hazaribagh, Jharkhand, and Patna, Bihar, where malpractice was allegedly rampant.

In response, the Court analyzed whether the breaches were widespread or localized and examined the feasibility of separating tainted from untainted candidates.

D) FACTS OF THE CASE

1. NEET (UG) 2024 was conducted on 5 May 2024 for approximately 23 lakh candidates across 4750 centers in 571 cities, including 14 overseas centers.
2. Post-exam, reports emerged of a question paper leak at centers in Hazaribagh and Patna. Investigations were launched by state authorities and later transferred to the Central Bureau of Investigation (CBI).
3. Compensatory marks were granted to 1563 candidates, raising further concerns regarding fairness.
4. The Director of IIT Madras conducted data analytics to assess anomalies. The Court reviewed reports indicating no evidence of systemic malpractice.
5. Recommendations included enhancing security protocols, improving oversight, and forming an expert committee for future reforms.

E) LEGAL ISSUES RAISED

1. Was the integrity of the NEET (UG) 2024 compromised at a systemic level?
2. Could the tainted candidates be segregated from the untainted ones?
3. Should a re-test be ordered to ensure fairness?

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Petitioners argued that a widespread leak undermined the examination’s integrity, demanding cancellation and a re-test.
2. They pointed to discrepancies in marking, with compensatory marks awarded unequally to certain candidates.
3. Alleged systemic lapses included delayed transportation of question papers, improper handling, and inadequate security.
4. Claimed that the Director of IIT Madras was conflicted due to his association with the NTA.

G) RESPONDENT’S ARGUMENTS

1. The Solicitor General for the Union and NTA refuted allegations of systemic malpractice, citing isolated incidents of irregularities.
2. They emphasized that the Director of IIT Madras acted impartially in analyzing data and found no abnormal patterns.
3. A re-test would unfairly burden over 2 million candidates, causing significant delays and logistical issues.
4. Strict protocols were followed, and compensatory marks were granted to ensure fairness.

H) JUDGMENT

a. Ratio Decidendi:
The Court held that the breaches were localized and identifiable. The ability to segregate tainted candidates precluded the need for a re-test. It directed the NTA and Union Government to rectify procedural lapses and ensure stricter safeguards in the future.

b. Obiter Dicta:
The judgment emphasized the need for data security, administrative oversight, and technological enhancements in competitive exams.

c. Guidelines (if any):

1. Formation of a seven-member expert committee to recommend reforms.
2. Implementation of real-time monitoring, tamper-evident packaging, and secure logistics.
3. Regular audits and CCTV surveillance of examination centers.

I) CONCLUSION & COMMENTS

The judgment balances the interests of affected candidates with the larger body of students. It underscores the importance of administrative reforms and technological upgrades to uphold the integrity of competitive exams.

J) REFERENCES

a. Important Cases Referred:

1. Kanpur University v. Samir Gupta [1984] 1 SCR 73
2. Sachin Kumar v. Delhi Subordinate Service Selection Board (2021) 4 SCC 631
3. Bihar School Examination Board v. Subhas Chandra Sinha (1970) 1 SCC 648

b. Important Statutes Referred:

• Article 32, Constitution of India