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Issues:
1. Challenge against the order of cancellation of examinations at Hanswadih Centre by Bihar School Examination Board. 2. Violation of principles of natural justice and fair play in the decision-making process. 3. Competence of the Chairman to pass the order under Bihar School Examination Board Regulations. 4. Justification of cancellation of examinations due to unfair means practiced on a mass scale. Analysis: 1. The case involved an appeal against the judgment of the High Court of Patna, where the Board had canceled the annual Secondary School Examination of 1969 at Hanswadih Centre due to suspected unfair means. The respondents, students of two schools, challenged this order, seeking the publication of their results. The High Court quashed the cancellation order, citing a lack of natural justice in the decision-making process. 2. The High Court found that while suspicions of unfair means were justified, the Board failed to provide the examinees with an opportunity to present their case or disclose the materials on which the decision was based. It emphasized the importance of natural justice and fair play, citing precedents like Board of High School & Intermediate Education, U.P., Allahabad v. Ghanshyam Das Gupta. The High Court also criticized the short interval between the cancellation announcement and the Supplementary Examination. 3. The competence of the Chairman to pass the cancellation order under the Board's Regulations was questioned. However, it was clarified that under the Bihar School Examinations Board Act, the Chairman had the authority to act in emergencies, with subsequent approval from the Board. The cancellation was deemed an order of the Board, thus valid under the Act. 4. The core issue revolved around the justification for canceling the examinations due to the widespread adoption of unfair means at Hanswadih Centre. The Supreme Court, after reviewing expert reports and answer books, confirmed the mass-scale adoption of unfair means. It concluded that the cancellation was necessary to maintain academic standards and upheld the Board's decision. The Court emphasized that in cases where the examination as a whole is vitiated, individual representation is not required, and the decision to cancel the examination was justified based on clear evidence. In conclusion, the Supreme Court set aside the High Court's order, dismissing the writ petition and upholding the cancellation of examinations at Hanswadih Centre by the Bihar School Examination Board.
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