University revaluation powers permit limited re-verification, but unreliable revised results may be cancelled and supplemented by re-examination.
A university Vice-Chancellor may exercise express or implied supervisory powers to order re-verification, re-valuation or re-examination of answer scripts where the statutory scheme permits and the action is not arbitrary, unreasonable or mala fide. At the same time, a revised result based on a pressure-induced, limited and unreliable re-verification process may be cancelled by the competent academic authority. On the facts noted, the Executive Council was justified in disapproving the exercise, cancelling the revised results and directing failed students to reappear, while a supplementary examination was upheld as appropriate relief for affected students.
Issues: (i) Whether the Vice-Chancellor had jurisdiction under the University Act to direct re-verification, re-valuation or re-examination of answer scripts. (ii) Whether the Executive Council was justified in cancelling the revised results and directing the failed students to reappear in the examination.
Issue (i): Whether the Vice-Chancellor had jurisdiction under the University Act to direct re-verification, re-valuation or re-examination of answer scripts.
Analysis: The Vice-Chancellor, as the principal executive and academic officer, has general supervision and control over the affairs of the University and may take immediate action where necessary. The statutory scheme, read with the power of the Executive Council to make statutes, also recognises the Vice-Chancellor's express and implied authority to ensure that the Act, Statutes, Ordinances and Regulations are duly observed. Re-evaluation of answer scripts is not barred merely because no specific provision expressly authorises it; in an appropriate case, academic authorities may order such exercise if the decision is not arbitrary, unreasonable or mala fide.
Conclusion: The Vice-Chancellor did have the power to order re-verification or re-evaluation of answer scripts.
Issue (ii): Whether the Executive Council was justified in cancelling the revised results and directing the failed students to reappear in the examination.
Analysis: The material showed that the re-verification was ordered under pressure from students and parents, was confined only to a limited set of candidates, and was not shown to have been undertaken on any proper or reliable methodology. The University did not independently examine the complaints on merits before undertaking the exercise, and the process was completed in a manner that undermined its credibility. In those circumstances, the Executive Council was justified in disapproving the exercise and cancelling the revised results. The direction to hold a supplementary examination for the students who had not cleared the paper was also appropriate relief.
Conclusion: The Executive Council was justified in cancelling the revised results and directing the failed students to reappear, and that part of the High Court's decision was upheld.
Final Conclusion: The appeals did not warrant interference with the ultimate result, though the Court affirmed the limited relief of a supplementary examination for the affected students.
Ratio Decidendi: Where an academic authority acts within its supervisory and emergent statutory powers, re-evaluation is permissible in an appropriate case, but a revised result based on an unverified, pressure-induced and unreliable process may validly be cancelled by the competent authority.
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