VANSHIKA YADAV vs. UNION OF INDIA AND OTHERS

Case Analysis

VANSHIKA YADAV vs. UNION OF INDIA AND OTHERS

A) ABSTRACT / HEADNOTE

This case, Vanshika Yadav v. Union of India and Others (Writ Petition (Civil) No. 335 of 2024), revolves around the National Eligibility-cum-Entrance Test (NEET) UG 2024. Allegations surfaced of systemic deficiencies and the leakage of question papers at specific centers in Bihar and Jharkhand. The Central Bureau of Investigation (CBI) identified 155 students benefiting from the malpractice. The Supreme Court addressed whether these issues necessitated canceling the examination or conducting a retest, affecting over two million candidates. After detailed scrutiny, the Court concluded that there was insufficient evidence of a systemic breach or widespread compromise. A fresh examination was deemed impractical due to cascading impacts on medical admissions and marginalized communities. The Court emphasized segregating fraudulent candidates and directed revisions to the results based on expert advice on disputed questions.

Keywords: NEET (UG) 2024, examination sanctity, question paper leakage, systemic deficiencies, data analytics.

B) CASE DETAILS

i) Judgment Cause Title:

Vanshika Yadav v. Union of India and Others

ii) Case Number:

Writ Petition (Civil) No. 335 of 2024

iii) Judgment Date:

23 July 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] 7 S.C.R. 957

viii) Legal Provisions Involved:

Article 32 of the Constitution of India
Relevant principles in Tanvi Sarwal v. Central Board of Secondary Education (2015) and Sachin Kumar v. DSSSB (2021).

ix) Judgments overruled by the Case (if any):

None

x) Case is Related to which Law Subjects:

Education Law, Constitutional Law, Administrative Law

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The National Testing Agency (NTA) conducted NEET (UG) 2024 for admissions to undergraduate medical courses, involving over two million candidates. Allegations of question paper leakage emerged, with claims of systemic irregularities affecting examination sanctity. The case was filed to seek a retest, citing precedents where exams were canceled due to systemic malpractices. The Supreme Court analyzed whether the sanctity of NEET (UG) 2024 was compromised and if a retest would balance fairness with practicality.

D) FACTS OF THE CASE

NEET (UG) 2024 was conducted across 4,750 centers in 571 cities, including 14 overseas locations. Approximately 23,33,297 candidates competed for 1.08 lakh seats, including reserved quotas.
Reports surfaced of question paper leakage at Hazaribagh (Jharkhand) and Patna (Bihar) centers. Investigations revealed at least 155 students benefitted.
The CBI, tasked with probing the malpractice, reported ongoing investigations, confirming fraud but denying systemic breaches across all centers.
Petitioners argued systemic deficiencies in exam conduct and sought a complete annulment of NEET 2024, relying on judgments in Tanvi Sarwal and Sachin Kumar.
Expert bodies, including IIT Madras, analyzed data trends from 2022 to 2024, finding no widespread abnormalities. A committee from IIT Delhi resolved disputed questions on the answer key.
The Union Government constituted a seven-member Expert Committee to strengthen examination processes and prevent future leaks.

E) LEGAL ISSUES RAISED

i) Whether the sanctity of NEET (UG) 2024 was compromised due to systemic deficiencies and malpractice?

ii) Whether conducting a fresh examination would serve justice and fairness for all candidates?

iii) Whether segregating fraudulent candidates from untainted ones was feasible within the current system?

F) PETITIONER/APPELLANT’S ARGUMENTS

Systemic Leak Allegations: Petitioners contended that question paper leakage was systemic and affected examination integrity, citing the malpractice’s occurrence in two states.
Reliance on Precedents: Citing Tanvi Sarwal and Sachin Kumar, petitioners argued that exams were previously annulled due to localized malpractices.
Unfair Advantage: The petitioners claimed the fraud provided an undue advantage to some candidates, warranting a fresh test.
Impact on Justice: They argued that the existing structure did not ensure fairness for untainted candidates, necessitating broader systemic reforms.

G) RESPONDENT’S ARGUMENTS

Investigation Findings: Respondents highlighted the limited scope of malpractice (155 students out of over two million), asserting no systemic irregularity across centers.
Impact of Retest: Conducting a fresh test would disrupt academic schedules, delay medical education, and adversely affect marginalized students.
Data Analysis Reports: Respondents relied on IIT Madras and NTA reports, which did not substantiate systemic deficiencies across the examination.
Proposed Solutions: They advocated revising results based on verified data and compensatory testing for affected students, avoiding widespread disruptions.

H) JUDGMENT

a. RATIO DECIDENDI

The Supreme Court determined that the NEET (UG) 2024 examination’s integrity was not compromised systemically. It emphasized:

Isolating fraudulent candidates using robust data analysis.
Revising results with accurate answer keys.
Balancing fairness with practical implications for untainted candidates.

b. OBITER DICTA

The Court underlined the need for long-term systemic reforms in NTA-conducted examinations to enhance transparency and prevent future leaks.

c. GUIDELINES

Conduct forensic and data-driven investigations for segregating tainted candidates.
Update NEET results based on verified answer keys and exclude fraudulent candidates.
Implement stringent checks and balances in future examinations to ensure fairness.

I) CONCLUSION & COMMENTS

The Court’s decision reflects a pragmatic balance between justice for affected students and the broader interests of two million candidates. By rejecting a fresh examination, it avoided cascading delays while addressing malpractice robustly. The judgment reinforces the importance of systemic reforms and highlights data analytics as a tool for ensuring exam integrity.

Case Analysis