A) ABSTRACT / HEADNOTE

The Supreme Court of India scrutinised the Common Law Admission Test (CLAT) 2024–25 evaluation controversies and intervened in six disputed questions, balancing its usual restraint in academic matters with the compelling need to safeguard candidates’ rights. Recording “deep anguish” at the Consortium of National Law Universities’ “callous and casual” question-setting, the Court endorsed limited, question-wise correction and deletion rather than wholesale re-assessment.

It recognised that the reading-material model permits a test-taker using only logic and the supplied text to answer, and then applied that benchmark to: award marks to candidates selecting either option (c) or (d) for Question 56 on environmental duties; uphold option (b) as correct for Question 77 on voidable contracts; affirm option (c) for Question 78 on void agreements; delete Question 88 given parity with a previously deleted, near-identical item; and delete Questions 115 and 116 because they required excessive computation and cross-referencing errors undermined fairness.

The Court relied on Articles 48A, 51A(g), and 21 to locate a shared State-citizen environmental duty and cited Disha Panchal v. Union of India to emphasise remedial oversight of entrance examinations. It directed the Consortium to amend the key, revise mark sheets, republish lists, and commence counselling within two weeks of the order dated 7 May 2025.

The ruling refines the standard for judicial intervention in high-stakes competitive exams, insisting on accuracy, internal coherence, and candidate equity without supplanting academic autonomy.

Keywords: CLAT; judicial review in academic matters; answer-key correction; environmental duties under the Constitution; void/voidable contracts; equitable treatment of candidates; deletion of flawed questions.

B) CASE DETAILS 

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appeal arose from a Delhi High Court Division Bench decision dated 23 April 2025 which had, following transfers of writ petitions from across High Courts, adjudicated disputes over several CLAT questions and the corresponding answer key. The Supreme Court, noting that it ordinarily refrains from delving into academic domains, invoked an exception: when the conduct of academic bodies “adversely affects the career aspirations of lakhs of students,” judicial correction is warranted.

The Bench foregrounded its concern with the Consortium’s quality control, echoing earlier institutional unease expressed in Disha Panchal and Others v. Union of India, where examination mismanagement prompted directions for governmental oversight and systemic reform. In the present matter, the Supreme Court limited its focus to six questions (Nos. 56, 77, 78, 88, 115 and 116) because the High Court’s broader directions had already addressed other items, and because discrete, item-wise review best preserves academic autonomy while restoring fairness.

The Court engaged the reading-material model adopted by CLAT, under which candidates should be able to answer using the passage itself and logic and reason, without prior specialised knowledge. Applying this standard, it tested whether each impugned item cohered with its accompanying text, whether alternative options were tenable, and whether evaluation was evenhanded across test forms.

This approach yielded calibrated relief: acceptance of multiple correct options where the passage clearly supported more than one reading; recognition of voidable and void distinctions drawn directly from the supplied primer under the Indian Contract Act, 1872; deletion of items where parity and internal consistency demanded it; and removal of data-heavy or cross-referenced questions inconsistent with an objective-type format.

The institutional censure was pointed: the Court recorded “deep anguish” at the Consortium’s “callous and casual” drafting and mandated immediate downstream rectifications—amended answer key, revised mark sheets, republication, and counselling within two weeks—to stabilise the admissions timeline.

D) FACTS OF THE CASE

A cohort of candidates challenged aspects of CLAT evaluation, contending that several questions and answers were erroneous or unsustainable under the test’s own reading-material paradigm. The Delhi High Court had entertained transferred writ petitions alongside a Letters Patent Appeal against a Single Judge’s decision dated 20 December 2024, culminating in a composite order on 23 April 2025.

Before the Supreme Court, the appellants—represented by Shri K.K. Venugopal and Shri Gopal Sankaranarayanan, Senior Advocates—sought relief confined to Question Nos. 56, 77, 78, 88, 115 and 116, maintaining that these items distorted merit and prejudiced ranks. The Consortium, through Shri Raj Shekhar Rao, Senior Advocate, defended its answer choices and the High Court’s limited interference, while also acknowledging deletion of one related item (Question 85), thereby placing parity issues squarely in contest for Question 88. The Court reviewed the question-wise materials.

Question 56 concerned environmental duties grounded in Articles 48A, 51A(g), and 21, and an asserted right against climate change reflected in a 21 March 2024 Supreme Court pronouncement cited in the reading text; the Consortium insisted only option (d) was correct, while the appellants argued that the passage expressly recognised a shared State-citizen duty, validating option (c) as well. Questions 77 and 78 were tethered to a reading note summarising Sections 2(h), 2(a), 2(i), 2(d), 14, 15, 16(3), and 24–28 of the Indian Contract Act, 1872, distinguishing void, voidable, and valid agreements; the parties disputed whether prior legal knowledge was indispensable and whether particular options accurately mapped to the primer.

Question 88 depended on a circular seating puzzle whose cognate item, Question 85, the Consortium had already deleted; parity and consistency therefore became decisive. Questions 115 and 116 were anchored to wage-gap statistics drawn from the World Inequality Report 2022 and other data; the former demanded computations to infer women’s wages given a state-specific percentage gap, and the latter suffered cross-referencing errors across sets, prompting arguments about candidate equity and the feasibility of objective testing demands.

These factual matrices framed the Supreme Court’s precise, remedial interventions and its institutional admonition to the examining body.

E) LEGAL ISSUES RAISED

The controversies crystallised into pointed questions of law and testing design, framed under the CLAT model that relies on self-contained passages. First, whether, on the text supplied with Question 56, the Constitution imposes environmental preservation as a fundamental duty solely upon the State or concurrently upon citizens, and thus whether options (c) and (d) were both defensible answers in light of Articles 48A, 51A(g), and 21 as reflected in the passage.

Second, whether Question 77 could be answered by a candidate using only the reading excerpt—without prior knowledge of the Indian Contract Act, 1872—or whether it was “out of syllabus,” and, consequently, whether the correct classification of the minor-involved agreement was “voidable”. Third, whether the scenario in Question 78 most likely resulted in a “void agreement” under the primer, specifically where an agreement promised remuneration contingent upon securing a government job.

Fourth, whether, given the deletion of Question 85, the structurally similar Question 88 should also have been deleted to maintain parity and avoid internal inconsistency in logical-reasoning evaluation. Fifth, whether Question 115’s computational demands exceeded the legitimate expectations of an objective test framed around comprehension and reasoning, thereby requiring deletion.

Sixth, whether Question 116—dependent on the information and cross-references associated with Question 115 and marred by set-wise errors—should be deleted across all sets to neutralise advantage and standardise scoring. These issues, taken together, required the Court to delineate the line between academic autonomy and judicial prophylaxis against arbitrariness in national, high-stakes admissions testing.

F) PETITIONER/APPELLANT’S ARGUMENTS

The appellants’ case, advanced by learned Senior Counsel, rested on fidelity to the reading-material model and the rule against penalising plausible readings that the passage itself affirmatively supports.

On Question 56, they highlighted the passage’s second sentence—“in many judgments, the Supreme Court ruled that both the State and its residents have a fundamental duty to preserve and protect their natural resources”—to show that option (c) was explicitly contemplated by the test’s own text; they argued that the Consortium’s insistence on option (d) alone ignored Articles 48A and 51A(g) and the jurisprudential arc of Article 21 as summarised in the material, which recognised a right against climate change while preserving the dual duty to protect nature.

They submitted that rewarding only option (d) would be arbitrary and contrary to the passage. On Question 77, they contended that the primer clearly distinguished voidable from void, stating that a voidable contract remains valid unless avoided at the instance of the disadvantaged party, and therefore a minor signatory renders the arrangement voidable at the minor’s option, aligning with Sections 2(h), 2(i) and 14–16 of the Indian Contract Act, 1872.

They rejected the High Court’s “out of syllabus” finding, demonstrating that the answer flowed from the text. On Question 78, they argued that the scenario of payment for securing a government job squarely implicated illegality and therefore a void agreement under the primer’s distinction between void and voidable agreements. Regarding Question 88, they underscored that Question 85 had been deleted by the Consortium, and the two items materially overlapped; retaining Question 88 while deleting Question 85 would be inconsistent and prejudicial.

On Questions 115 and 116, they pressed that the tasks required detailed mathematical analysis and suffered cross-referencing errors across sets, departing from the exam’s design and violating equality among candidates. Citing Disha Panchal v. Union of India, they urged that when exam conduct prejudices candidates systemically, courts must intervene with targeted, equitable relief.

G) RESPONDENT’S ARGUMENTS

The Consortium’s defence emphasised deference to academic expertise and the internal logic of its answer key. On Question 56, it maintained that only option (d) was correct, parsing the passage’s use of “State and its residents” to argue that the term “citizens” in option (c) did not precisely mirror the phrasing and that the test intended to focus on the State’s duty to maintain ecological balance alongside a judicially recognised right against climate change.

On Question 77, the Consortium argued that a candidate relying on the primer could reason to voidable as the correct classification, but suggested that such reasoning nonetheless drew upon a basic understanding of contractual capacity and consent, thus defending the High Court’s reluctance to broaden remedies. Still, it accepted that the passage sufficed for logical inference.

On Question 78, it firmly defended option (c) (the government job contingency) as the correct choice for a void agreement, consistent with the primer’s illegality discussion. Regarding Question 88, the Consortium initially took the position that the data was inadequate—option (d)—given the deletion of the related Question 85, and the High Court agreed not to interfere with that key; yet, it accepted that the material provided for both questions was the same, leaving the door open to parity review.

On Question 115, the Consortium suggested that the error lay in its own chosen option, and the High Court consequently decided to award marks only to those who attempted the item; however, the appellants contended that the computational burden itself was excessive. On Question 116, the Consortium fairly submitted before the Supreme Court that, to ensure uniform scoring, it was willing to withdraw the question across all four sets, acknowledging the cross-referencing error in certain sets and the dependency of Question 116 upon Question 115.

Through these positions, the Consortium urged minimal interference but expressed willingness to adopt uniform curative measures where necessary.

H) RELATED LEGAL PROVISIONS

The case implicated constitutional and statutory texts presented within the reading materials and the Court’s analysis. Environmentally, Article 48A directs the State to protect and improve the environment and to safeguard forests and wildlife, while Article 51A(g) imposes on every citizen the fundamental duty to protect and improve the natural environment.

The jurisprudence of Article 21—as summarised in the passage—recognises a right to a clean environment and, more recently, a right against climate change, which the text attributes to a Supreme Court verdict of 21 March 2024. Contractually, the primer engaged Sections 2(h) (contract), 2(a) (proposal), 2(i) (voidable contract), 2(d) (consideration), 14 (free consent), 15 (coercion), 16(3) (undue influence consequences), and 24–28 (agreements void) of the Indian Contract Act, 1872, delineating the axes of void, voidable, and valid and positioning agreements hinging upon illegal or opposed-to-public-policy objects as void.

The international context comprised India’s commitments under the Paris Agreement (COP-21)—including targets for renewable energy and net-zero by 2070—which the passage invoked to set the platform for Question 56’s environmental duty analysis. These texts, used as part of CLAT’s comprehension-plus-reasoning framework, provided the legal contour within which the Court assessed the defensibility of answer options and the permissibility of deletion where the question design outstripped the exam’s format constraints.

I) JUDGEMENT

The Supreme Court partly modified the Delhi High Court’s composite order, delivering calibrated, item-wise relief. For Question 56, the Court rejected the High Court’s view that only option (d) was correct. The passage itself declared that both the State and its residents have a fundamental duty to preserve and protect natural resources; accordingly, the Bench held that a candidate selecting option (c)—reflecting a State-citizen concurrent duty—deserved credit just as much as a candidate selecting option (d)—emphasising the State’s ecological obligations alongside a right against climate change.

The Court therefore directed positive marks for both options (c) and (d), and negative marks for (a) and (b). Turning to Question 77, the Court disagreed with the High Court’s “out of syllabus” characterisation. It found that even without prior legal knowledge, a test-taker could, by reading the primer, infer that an agreement signed by a minor is voidable at the minor’s option; option (b) was correct, and candidates choosing it must receive positive marks, while those choosing options (a), (c), or (d) would receive negative marks.

For Question 78, the Court affirmed the High Court’s stance that option (c)—the promise of 10 lakhs on getting a government job—exemplified a void agreement consistent with the primer’s illegality framework. Addressing Question 88, the Court emphasised parity: because the Consortium itself had deleted Question 85, which was closely related and based on the same seating-arrangement material, Question 88 ought also to be deleted.

On Question 115, the Court found that the problem demanded detailed mathematics analysis unsuited to an objective-type comprehension test, and therefore ordered deletion; it followed that Question 116, cross-referencing the same data and already acknowledged by the Consortium as problematic across sets, must also be deleted across all sets.

Finally, the Court directed the Consortium to amend the answer key, revise mark sheets, republish/notify the final list forthwith, and commence counselling within two weeks from 7 May 2025. The Court reiterated its institutional concern with CLAT governance, citing Disha Panchal for systemic oversight, but confined relief to specific, defensible corrections that preserved the examination’s integrity while erasing manifest arbitrariness.

a. RATIO DECIDENDI

The ratio rests on a two-fold principle calibrated for high-stakes, passage-based entrance examinations. First, when the testing body adopts a reading-material model, the lawfulness of a question and its key must be assessed against the four corners of the supplied text and the candidate’s ability to apply logic without prior technical knowledge.

This anchors judicial review to the exam’s own declared methodology, limiting intervention yet ensuring fidelity to the framework. Applying this, the Court held that Question 56’s passage unequivocally posited concurrent duties of State and citizens under Articles 48A and 51A(g) while also subsuming a right against climate change within Article 21; therefore, both options (c) and (d) were text-compliant answers meriting credit.

Second, where the construction of a question or its dependencies create inconsistency, excessive computational burdens, or cross-set inequities, deletion—not speculative re-keying—is the proportionate remedy. Thus Questions 115 and 116 were deleted for computational overreach and cross-referencing flaws, and Question 88 was deleted to maintain parity with the already deleted Question 85.

The ratio also clarifies that courts will intervene in academic matters when arbitrariness jeopardises candidate equity, invoking the institutional standard articulated in Disha Panchal v. Union of India, but will tailor relief to preserve academic autonomy by avoiding wholesale re-examination.

The operative rules that emerge are: credit all answers supported by the test’s own material; uphold keys only where exclusivity is textually compelled; and delete items whose design fatally compromises fairness or coherence. These holdings collectively demarcate the boundary between judicial correction and academic discretion in national entrance testing.

b. OBITER DICTA 

The Court’s prefatory and contextual remarks amount to consequential obiter shaping future conduct. It recorded “deep anguish regarding the callous and casual manner” in which the Consortium framed CLAT questions, signalling that academic autonomy does not immunise negligent exam design—especially where admissions to National Law Universities are at stake.

It recalled that in Disha Panchal and Others v. Union of India the Supreme Court had directed the Union to constitute a committee to examine CLAT conduct and consider penal action and structural reforms, including revisiting the model of outsourcing monitoring to rotating law universities.

The present Bench noted that a committee report exists and has been placed before the Court in WP(C) No. 600 of 2015, Shamnad Basheer v. Union of India, and observed that appropriate orders would follow in that proceeding, given the petitioner’s demise—an administrative signal that systemic CLAT governance issues remain under the Court’s gaze.

The obiter also reiterates a doctrinal caution: courts are generally reluctant to interfere in academic matters for want of expertise, but when academicians’ decisions impinge on lakhs of students, intervention becomes a necessity. This cautionary frame informs regulatory expectations for future CLAT cycles: clarity of passages, internal coherence of options, parity across sets, and avoidance of tasks that demand detailed mathematical computations inconsistent with objective comprehension.

These observations, while not dispositive of the parties’ immediate rights, chart a compliance roadmap for the Consortium and underscore the judiciary’s willingness to enforce minimum procedural and substantive fairness in nationwide entrance examinations.

c. GUIDELINES

The operative directions and embedded norms function as guidelines for future administration. First, where a passage supports more than one defensible option, both must be credited; in concrete terms, for Question 56, options (c) and (d) must receive positive marks, while plainly incorrect options incur negative marks. Second, where a question’s design imposes disproportionate computational analysis unsuited to an objective comprehension test, it should be deleted rather than partially salvaged; hence Question 115 stands deleted.

Third, where one item (e.g., Question 85) has been deleted and a cognate item (e.g., Question 88) relies on the same material and logic, parity requires deleting the cognate item too, forestalling inconsistent treatment. Fourth, where cross-referencing or set-wise discrepancies undermine uniformity (as with Question 116), deletion across all sets is necessary to place candidates on an equal footing.

Fifth, post-decision compliance must be prompt and transparent: the Consortium is directed to amend the answer key, revise mark sheets, republish/notify the final list forthwith, and commence counselling within two weeks from 7 May 2025. Sixth, academic restraint does not foreclose judicial correction of arbitrariness; therefore, exam bodies must embed quality controls to ensure that reading-material questions are self-contained and logically resolvable without prior specialised knowledge, reflecting the standard applied to Questions 77 and 78—where the Court upheld keys consistent with the primer under the Indian Contract Act, 1872.

Finally, institutional oversight remains live: the Court referenced the earlier committee process from Disha Panchal and its linkage to Shamnad Basheer, signalling that structural reforms to CLAT administration may be pursued separately. These guidelines, drawn directly from the Court’s directions and reasoning, articulate a framework of fairness, parity, and methodological integrity for future iterations of CLAT.

J) CONCLUSION & COMMENTS

The decision demonstrates a measured judicial hand: neither supplanting academic prerogatives nor tolerating evaluative arbitrariness. By crediting multiple correct answers where the passage permitted (Question 56), affirming a voidable classification derived from the primer’s own language (Question 77), and upholding an unambiguous void scenario (Question 78), the Court preserved the exam’s design logic.

By deleting items that threatened parity or demanded disproportionate computation (Questions 88, 115, 116), it enforced equity and internal coherence. The reliance on Articles 48A, 51A(g), and 21—as distilled within the passage—signals doctrinal continuity: environmental stewardship is a shared State-citizen duty while Article 21’s penumbra covers environmental quality and, as the passage conveys, a right against climate change.

The Court’s invocation of Disha Panchal shows that systemic oversight of entrance examinations is an enduring judicial concern. Significantly, the compliance timeline—answer-key amendment, mark-sheet revision, republication, and counselling within two weeks—reflects sensitivity to the admissions calendar, preventing protracted uncertainty. Going forward, the Consortium must institutionalise content validation, logical exclusivity of options, cross-set uniformity, and avoidance of tasks misaligned with objective testing.

The reading-material model should be treated as a contract with candidates: all necessary cues must lie within the text; answers must be deducible by reason alone; ambiguity must be either resolved ex ante or credited ex post. This decision thus fortifies examination fairness while preserving the core of academic autonomy, offering a template for principled, light-touch judicial correction when high-stakes evaluations falter.

K) REFERENCES

a. Important Cases Referred

i. Disha Panchal and Others v. Union of India through the Secretary and Others, 2018 INSC 553; (2018) 17 SCC 278; [2018] 5 SCR 12 (referred to for oversight and remedial principles in CLAT administration).

ii. Siddhi Sandeep Ladda v. Consortium of National Law Universities and Another, [2025] 7 S.C.R. 55; 2025 INSC 714 (principal case analysed).

iii. Shamnad Basheer v. Union of India and Others, WP(C) No. 600 of 2015 (noted as the proceeding where the committee report stands placed).

b. Important Statutes / Instruments Referred

i. Constitution of India, Articles 48A, 51A(g), and 21 (environmental duties and right to a clean environment).

ii. Indian Contract Act, 1872, Sections 2(h), 2(a), 2(i), 2(d), 14, 15, 16(3), and 24–28 (definitions and distinctions between void and voidable agreements).

iii. Paris Agreement (COP-21) (international environmental commitments referenced in passage context).

iv. World Inequality Report 2022 (background statistical data referenced in passages for Questions 115–116).