The High Court of Manipur has upheld the right of candidates to inspect their evaluated answer scripts in the Manipur Civil Services Combined Competitive Examination (MCSCCE), 2016 (2022), dismissing three writ petitions filed by the Manipur Public Service Commission (MPSC) against the Manipur Information Commission (MIC).
Justice A. Guneshwar Sharma ruled that while MPSC’s policy decisions dated May 4 and October 28, 2020 prohibit furnishing certified copies of evaluated descriptive answer scripts under normal circumstances, they do not bar candidates from inspecting their own answer scripts. The Court clarified that it was not examining the validity of the policy, as the issue is pending before a Division Bench.
The petitions 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 Commission.
Appearing for the MPSC, senior advocate M. Rarry, assisted by M. Nikita, 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 v. UPSC, which caution against disclosure of evaluated answer books as it may compromise the integrity of competitive examinations. He also submitted that the policy itself is under challenge before a Division Bench and should not be indirectly diluted through the present proceedings.
Senior advocate S. Rupachandra, assisted by Royal Salam, appearing for the RTI applicants, submitted that the original prayer in RTI applications is for furnishing certified copy of evaluated answer scripts of RTI applicants. He argued that the MPSC policy only prohibits supply of certified copies and does not prohibit inspection. Advocate S. Rupachandra further highlighted that even if original RTI applications are for furnishing certified copy of evaluated answer script, RTI applicants are satisfied with the relief moulded by State Information Commission of allowing them to peruse their own evaluated answer scripts for the said examination. K. Kishan, appearing for some of the applicants, adopted the submissions.
Appearing for the Manipur Information Commission, K. Roshan supported the impugned order, contending that inspection enhances transparency without compromising the confidentiality of the evaluation process.
The Court held that the Supreme Court’s ruling in Angesh Kumar dealt with disclosure of raw marks and evaluation methodology and was distinguishable from the present case. Instead, it relied on Mradul Mishra v. Chairman, U.P. Public Service Commission, in which the Supreme Court held that permitting a candidate to inspect his or her answer sheets does not affect public interest or the integrity of the examination system.
Holding that inspection is legally distinct from supplying certified copies, the Court dismissed the writ petitions and directed the MPSC to comply with the MIC’s order within 30 days. Parties were directed to bear their own costs.
