High Court Division bench upholds RTI applicants’ right to inspect MPSC answer scripts

A Division bench of the High Court of Manipur comprising Chief Justice M Sundar and Justice ABimol Singh has upheld the right of candidates to inspect their evaluated answer scripts in the Manipur Civil Services Combined Competitive Examination (MCSCCE), 2016 (2022), dismissing writ appeal filed by the Manipur Public Service Commission (MPSC) challenging a Single bench’s order.

The MPSC had challenged the single bench order where Justice A. Guneshwar Sharma ruled that while MPSC’s policy decisions dated May 4 and October 28, 2020 prohibits furnishing certified copies of evaluated descriptive answer scripts under normal circumstances, they do not bar candidates from inspecting their own answer scripts as ordered by the Manipur Information Commission (MIC). The single bench had clarified that it was not examining the validity of the policy, as the issue is pending before a Division Bench.

The MPSC had challenged a common order of the MIC directing the State Public Information Officer of MPSC to allow three RTI applicants to inspect their evaluated answer scripts after their requests for certified copies were rejected by the MPSC. The MIC order was issued when Oinam Sunil Singh was the State Chief Information Commissioner. After demitting his office in MIC, Oinam Sunil is currently serving as the Advisor (Media) to the Chief Minister.

The MIC, in its order dated April 28, 2023, passed in Appeal Case Nos. 16, 19 and 22 of 2023, directed the SPIO of MPSC to allow the three RTI applicants to inspect and examine their respective evaluated answer scripts for the MCSCCE Main Examination, 2016 (2022), within four weeks.

The MIC order passed by Oinam Sunil Singh as the State Chief Information Commissioner (SCIC) says “The State Information Commission, considering the practice adopted by High Court of Manipur in furnishing certified copy of evaluated answer sheets in the examination of Manipur Judicial Services; in order to maintain transparency involved in Civil Services Examination; past practice of MPSC of providing of certified copy of answer scripts for recruitment of Assistant Engineer in the year 2013; and considering pendency of the writ petition challenging policy decision not to furnish answer script before the High Court of Manipur, directed the SPIO of MPSC to allow the three RTI applicants (private respondents herein) to inspect and examine all their respective evaluated answer scripts for MCSCCE Main Examination, 2016 (2022) within four weeks from the date of the order.

The Division bench, in its order dated 12.08.2026 observed that it found no reason to disagree with the considered view taken by the Single bench in the impugned order. The Single bench had made it clear that the policy decision of the MPSC is only with regard to ‘not providing copies of evaluated answer sheets’ and it does not deal with ‘perusal of answer sheets’.

The MPSC has argued that the Commission’s policy was framed in line with the Supreme Court’s decisions in Union Public Service Commission v. Angesh Kumar and Prashant Ramesh Chakkarwar vs. UPSC, which caution against disclosure of evaluated answer books as it may compromise the integrity of competitive examinations.

The counsels for the RTI applicants submitted that the original prayer in RTI applications is for furnishing certified copy of evaluated answer scripts of RTI applicants. They argued that the MPSC policy only prohibits supply of certified copies and does not prohibit inspection. The counsel highlighted that even if original RTI applications are for furnishing certified copy of evaluated answer scripts, RTI applicants are satisfied with the relief provided by the State Information Commission of allowing them to peruse their own evaluated answer scripts for the said examination.

The Manipur Information Commission’s counsel supported the impugned order, contending that inspection enhances transparency without compromising the confidentiality of the evaluation process.

The division bench dismissed the writ petitions and upheld the Single bench’s order that directed the MPSC to comply with the MIC’s order within 30 days.

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