2011 (10) TMI 590 - SC - Indian Laws

Whether the procedure adopted by the Board to arrive at the cut off marks for JEE 2006 is arbitrary and mala fide and whether the High Court ought to have interfered in the matter?

Summary

Issues Involved:
1. Alleged anomalies and contradictions in the IIT-JEE 2006 selection process.
2. Arbitrary and malafide fixation of cut-off marks.
3. Validity of the procedure for determining cut-off marks.
4. Allegations of personal bias and manipulation by the Joint Admission Board (JAB).
5. Judicial review of academic decisions and policies.

Detailed Analysis:

1. Alleged anomalies and contradictions in the IIT-JEE 2006 selection process:
The appellants alleged that the cut-off marks for IIT-JEE 2006 were fixed arbitrarily and with malafides, leading to the exclusion of the first appellant despite his high aggregate marks. The second appellant, a professor at IIT Kharagpur, wrote to IIT authorities and filed RTI applications to gather data, revealing discrepancies in the information provided by the Organizing Chairman, JEE 2006 at different times.

2. Arbitrary and malafide fixation of cut-off marks:
The appellants contended that the cut-off marks were manipulated to exclude the first appellant. They presented expert reports showing that the cut-off marks for Chemistry, as per the disclosed formula, should have been significantly lower than 55. The High Court, however, found no material evidence to support the claim of manipulation or malafides.

3. Validity of the procedure for determining cut-off marks:
The respondents defended the procedure, explaining it was designed to ensure candidates had consistent performance across all subjects. The process involved calculating mean marks and standard deviations, followed by an iterative process to determine cut-off marks and the aggregate cut-off. The Supreme Court noted that while the procedure was complex, it was neither arbitrary nor discriminatory and aimed to select candidates with balanced proficiency in all subjects.

4. Allegations of personal bias and manipulation by the Joint Admission Board (JAB):
The appellants alleged that the JAB Chairman and Organizing Chairman harbored personal grudges against the second appellant, leading to the manipulation of cut-off marks. The Supreme Court found these allegations to be baseless and unsupported by any evidence. It emphasized that it was implausible to believe that the process was manipulated to exclude one candidate among nearly 300,000.

5. Judicial review of academic decisions and policies:
The Supreme Court reiterated that courts should be reluctant to interfere in academic matters unless there is evidence of violation of statutory provisions, malafides, or arbitrary actions. The Court cited precedents emphasizing that academic decisions should be left to professional bodies with technical expertise. It concluded that the procedure adopted by the JAB, though complicated, was aimed at achieving a balanced selection and was not arbitrary or capricious.

Conclusion:
The Supreme Court dismissed the appeal, upholding the High Court's decision. It recognized the appellants' efforts in bringing transparency to the ranking process but found no grounds for judicial interference in the absence of evidence of malafides or arbitrariness. The judgment highlighted the importance of allowing academic bodies to evolve and refine their selection processes without undue judicial intervention.