No-evidence finding and disproportionate academic punishment led to quashing of disciplinary action and restoration of examination rights.

A disciplinary finding of exam personation was quashed where the only material was a bare visual handwriting comparison, unsupported by expert, microscopic, or corroborative evidence. The Court held that the no-evidence rule applies where relied-on material lacks probative value and cannot rationally sustain the conclusion, and that the finding was perverse and contrary to natural justice. It also held that academic punishment must be reasonable and proportionate; the five-year debarment was grossly excessive and arbitrary, so interference in writ jurisdiction was justified. The examination result was to be declared and the student permitted to attend classes on that basis.

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Issues: (i) Whether the disciplinary finding of personation at the examination was vitiated by the absence of evidence in law and by perversity; (ii) whether the penalty of five years' debarment was so disproportionate as to warrant interference in writ jurisdiction.

Issue (i): Whether the disciplinary finding of personation at the examination was vitiated by the absence of evidence in law and by perversity.

Analysis: The only substantive material against the student was a bare visual comparison of handwriting in the answer books, with no expert assistance, microscopic enlargement, or other intrinsic or corroborative material. The so-called comparison evidence was held to be at best suspicious and not reasonably capable of supporting the conclusion of guilt. The Court held that the "no evidence" rule is attracted not only where there is a complete absence of evidence, but also where the material lacks probative value or cannot rationally sustain the finding. On the facts, the finding was also held to be perverse and contrary to natural justice.

Conclusion: The finding of misconduct was invalid and liable to be quashed.

Issue (ii): Whether the penalty of five years' debarment was so disproportionate as to warrant interference in writ jurisdiction.

Analysis: The Court held that disciplinary punishment in the academic field must be reasonable and proportionate, and that arbitrariness in the quantum of penalty is amenable to judicial review under Article 14. The Court further observed that relevant personal and surrounding circumstances must be taken into account when fixing penalty, and that a uniform or excessive punishment may be unfair and arbitrary. On the facts, the five-year debarment was regarded as grossly excessive.

Conclusion: The penalty was disproportionate and could not be sustained.

Final Conclusion: The disciplinary decision was set aside and the University was directed to declare the examination result and permit the student to attend classes on the basis of that result.

Ratio Decidendi: In writ jurisdiction, a disciplinary finding is liable to be quashed where the material relied upon has no real probative value or cannot reasonably support the conclusion reached, and punishment may also be interfered with if it is so disproportionate as to be arbitrary and unreasonable.

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