{"id":223384,"date":"1970-03-10T00:00:00","date_gmt":"1970-03-09T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/bihar-school-examination-board-vs-subhas-chandra-sinha-ors-on-10-march-1970"},"modified":"2016-09-18T14:33:29","modified_gmt":"2016-09-18T09:03:29","slug":"bihar-school-examination-board-vs-subhas-chandra-sinha-ors-on-10-march-1970","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/bihar-school-examination-board-vs-subhas-chandra-sinha-ors-on-10-march-1970","title":{"rendered":"Bihar School Examination Board vs Subhas Chandra Sinha, & Ors on 10 March, 1970"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Bihar School Examination Board vs Subhas Chandra Sinha, & Ors on 10 March, 1970<\/div>\n
Equivalent citations: 1970 AIR 1269, \t\t 1970 SCR (3) 963<\/div>\n
Author: M Hidayatullah<\/div>\n
Bench: Hidayatullah, M. (Cj)<\/div>\n
           PETITIONER:\nBIHAR SCHOOL EXAMINATION BOARD\n\n\tVs.\n\nRESPONDENT:\nSUBHAS CHANDRA SINHA, & ORS.\n\nDATE OF JUDGMENT:\n10\/03\/1970\n\nBENCH:\nHIDAYATULLAH, M. (CJ)\nBENCH:\nHIDAYATULLAH, M. (CJ)\nRAY, A.N.\nDUA, I.D.\n\nCITATION:\n 1970 AIR 1269\t\t  1970 SCR  (3) 963\n 1970 SCC  (1) 648\n CITATOR INFO :\n R\t    1978 SC 851\t (58,69)\n\n\nACT:\nNatural Justice-Evidence of unfair means at examination at a\nparticular  centre apparent-Cancellation of  examination  at\nthe centre Whether notice to examinees necessary.\nBihar School Examination Board Act (Bihar Act 7 of 1952)  s.\n9 (3) Scope of.\n\n\n\nHEADNOTE:\nCandidates at the Secondary School Examination held in March\n1969,  appeared\t at  various centers.  The  results  at\t all\ncentres\t were  published  in July 1969, except\tthose  at  a\nparticular  centre.  The tabulators at that centre  reported\nthat  the percentage of marks and of  successful  candidates\nwas  unusually high (80% or more).  The matter was  referred\nto  tile Unfair Means Committee of the Board.  A  comparison\nof the answer books at that centre showed such a  remarkable\nagreement  in the answers, that it was obvious\tthat  unfair\nmeans were adopted and that the students had assistance from\nan  outside source.  The Chairman passed an order on  August\n30,  1969,  cancelling\tthe examination at  the\t centre\t and\nallowing  the  examinees at the centre to  reappear  at\t the\nSupplementary  Examination  in September The action  of\t the\nChairman was placed before the Board and was- approved.\nThe  respondents,  who were the examinees  at  that  centre,\nmoved  the  High  Court under Art. 226 and  the\t High  Court\nquashed\t the order of\" the Board and ordered publication  of\nthe results of that centre.,\nIn appeal to this Court,\nHELD:(1) There was enough material for the Chairman and\t the\nBoard for taking action without any' complaint from  anybody\nof the Use of unfair means. [966 E-F]\n(2)  There was no reason for withholding the publication  of\nresults,  of other centres which were not under\t suspension.\n[966 F]\n(3) Under s. 9(3) of the Bihar School Examination Board Act.\nin an emergency, the powers of the Chairman are\t co-terminus\nwith  those of the Board and be can take action himself\t and\nlater  report it to the Board.\tTherefore, the order of\t the\nChairman in the present case was not incompetent. [966\tC-F;\n967 A]\n(4) The essence of an examination is that the worth of every\nis appraised without any assistance from an outside  source.\nIf  at\ta  centre  the\twhole  body  of\t students   received\nassistance   and  managed  to  source  success\tat  a\thigh\npercentage, when at other centres, the average was only 50%,\nthe University or the Board could cancel the examination  as\na  whole; and if there was -sufficient material on which  it\ncould  be demonstrated that the Authority was right  in\t its\nconclusion that the examination as a whole was vitiated then\nacademic standards require that the Authority's appreciation\nof the -problem must be respected.  To make such a  decision\ndepend\tupon a full-fledged judicial inquiry would  hold  up\nthe  functioning of such autonomous bodies  as\tUniversities\nand School Boards. [967 G-H; 968 E-H]\n964\nIn  the\t present case, no principle of natural\tjustice\t was\nviolated  and  there was no need to give  the  examinees  an\nopportunity to contest the conclusion, because, the evidence\nwas  plain and transparent, and the Board had  not  charged-\nanyone\twith unfair means so that he could claim  to  defend\nhimself.  Therefore, the order of the High Court must be set\naside and the respondents-candidates allowed to sit for\t the\nnext examination. 1969 B-D]\nBoard\tof   High  School  Intermediate\t Examination,\tU.P.\nAllahabad  v.  Ghanshyam Das Gupta and Ors.<\/a> [1962]  Supp.  3\nS.C.R. 36, explained..\n\n\n\nJUDGMENT:\n<\/pre>\n
CIVIL  APPELLATE  JURISDICTION : Civil Appeal  No.  2620  of
\n1969.\n<\/p>\n
Appeal\tby special leave from the judgment and\torder  dated
\nDecember  8,  1969 of the Patna High Court in  C.W.J.C.\t No.
\n1040 of 1969.\n<\/p>\n
Sarjoo\tPrasad,\t Roy  Paras Nath, S. K. Bisaria\t and  S.  S.
\nJahar, for the appellant.\n<\/p>\n
S. N. Prasad, for the,respondents.\n<\/p>\n
The Judgment of the Court was delivered by
\nHidayatullah,  C.J., This is an appeal against the  judgment
\nand  order of the High Court of Patna, December 8,  1969  in
\nCivil  Writ  Jurisdiction  Case No. 1040  of  1969.   It  is
\nbrought\t to this Court by special leave.  The  appellant  is
\nthe  Bihar  School Examination Board through  its  Chairman.
\nThe   respondents  are\t36  students  of  S.S.H.E.   school,
\nJagdishpur and H. E. School Malaur, District Shahabad.\tThey
\nhad moved the High Court under Art. 226 of the\tConstitution
\nagainst\t the order of the Board cancelling annual  Secondary
\nSchool\tExamination of 1969 in relation to Hanswadih  centre
\nin  Shalibad District.\tThey had also asked that a  mandamus
\nbe  issued  to\tthe  Board to publish  the  results  of\t the
\nstudents  who appeared at this centre.\tThe High  Court\t has
\nquashed the order of cancellation and directed the Board  to
\npublish the results.\n<\/p>\n
Candidates  at\tthe  Secondary School  Examination  held  in
\nMarch, 1969 appeared at various centres including  Hanswadih
\nCentre.\t  The  results were published in July 1969  but\t the
\nresults of examinees at Hanswadih centre were not  released.
\nOn  July  22, 1969 it was reported in a\t local\tHindi  daily
\nnewspaper  that the results of this centre and\tothers\twere
\nunder  consideration.  On August 30, 1969 a communique\tfrom
\nthe  Board  appeared in the newspaper Searchlight  that\t the
\nexaminations  of all subjects held at the  Secondary  School
\nExamination of. 1969 at Hanswadih centre were cancelled\t and
\nthe  reason was that unfair means were practiced on a  large
\nscale  at this Centre.\tExaminees were, however, allowed  to
\nappear at the supplementary Secondary School Examination  to
\nbe held in September, 1969.\n<\/p>\n
 96 5
\nThe  respondents challenged the order of the Board  on\tmany
\ngrounds.  The main grounds were that there was no  complaint
\nof  use of unfair means; that no opportunity had been  given
\nto  the examinees to show cause before passing the order  of
\ncancellation   against\tthem;  that  as\t the   Supplementary
\nExamination was to be held within 10 days of the  communique
\nthere  was  no\ttime for the students  to  prepare  for\t the
\nexamination;  that  the\t cancellation  ought  to  have\tbeen
\nannounced  before, publishing the results of  other  centres
\nand lastly that the order passed by the Chairman and not  by
\nthe  Board,  was not a valid order under  the  Bihar  School
\nExamination Board Regulations.\n<\/p>\n
From  the record of the case and the return which  has\tbeen
\nfiled by the Board the following facts appear
\nThe  Tabulators of the Hanswadih centres’ reported that\t the
\npercentage  of\tsuccessful  examinees was  as  high  as\t 80%
\nwhereas the average at the Arrah, Dalippur centres was\tonly
\n50%.   They  were  therefore  asked  to\t prepare  percentage
\nsubject\t  wise.\t   All\tthe   Tabulators   submitted   these
\nprecentages.   The matter was referred to the  Unfair  Means
\nCommittee of the Board.\t The Committee in its turn asked the
\nModerators  to\tlook  into all the answer  books  where\t the
\npercentage was 80% or more.  They reported unfair means on a
\nmass scale.  The Chairman then passed an order on August 30,
\n1969  cancelling  the  examination in all  subjects  at\t the
\nHanswadih  Centre allowing the examinees to reappear at\t the
\nSupplementary Examination in September, 1969 without payment
\nof  fresh  fees.   The Head Masters  of\t the  three  schools
\nconcerned  were\t also informed by registered  letters.\t The
\naction\tof the Chairman was placed before the Board  at\t its
\nmeeting\t on  September\t9, 1969 and was\t approved.   It\t was
\nstated in the return that a complaint was received from\t one
\nSatnarain Singh of Jagdishpur, who, however, wrote a  letter
\nthat he had made no such complaint.\n<\/p>\n
The High Court gave a finding that the high percentages\t did
\ngive  rise to a suspicion that unfair means  were  practised
\nand that the Board was justified in investigating the  case.
\nIt  was, however, held that the examinees were not  given  a
\nchance to show cause and the materials on which the Chairman
\nof  the\t Board passed his order were not  disclosed  to\t the
\nexaminees.  The Board had therefore failed to act  according
\nto  the principles of natural justice and the order  of\t the
\nChairman   and\/or  the\tBoard  could  not,   therefore,\t  be
\nsustained.  The High Court relied upon Board of High  School
\n&  Intermediate Education, U.P., Allahabad v. Ghanshyam\t Das
\nGupta  and  others<\/a>(1) and Ajit Singh and  others  v.  Ranchi
\nUniversity(2).\tIt commented upon the short interval bet-
\n(1) [1962] Supp. 3 S.C R. 36.\n<\/p>\n
\t\t (2) A.I.R. 1964 Patna 291.\n<\/p>\n
96 6
\nween  the communique and the Supplementary  Examination\t and
\nheld that the communique should have been issued before\t the
\nresults had been published.  The High Court also  considered
\nthe  competence of the Chairman to pass the order under\t the
\nRegulations  but  did  not  decide  it\tas  it\treached\t the
\nconclusion  that  the  principles of  natural  justice\twere
\nviolated  and  the orders of the Chairman and\/or  the  Board
\nwere,  therefore unsustainable.\t The order of the Board\t was
\nquashed and the publication of the results of the  Hanswadih
\nCentre\twas ordered.  This Court granted special  leave\t and
\ndirected  stay\tof the operation of the order  of  the\tHigh
\nCourt.\n<\/p>\n
We  heard this appeal on February 25, 1970.  Since the\tnext
\nexamination at which the respondents can appear is scheduled
\nto  be held in March, we did not wish to delay the  decision
\nof the appeal.\tWe accordingly passed an order allowing\t the
\nappeal and set aside the order of the High Court but  stated
\nthat  we  would\t give our detailed reasons  later.   We\t now
\nproceed to do so.\n<\/p>\n
All  the  arguments which were presented in the\t High  Court
\nwere  repeated\tbefore\tus by the learned  counsel  for\t the
\nrespondents  We find it convenient to consider some of\tthem
\nbefore\ttaking\tup  the point on which the  High  Court\t has
\ncancelled   the\t order\tof  the\t Board\tand   directed\t the
\npublication of the results.\n<\/p>\n
The  argument  that no one had complained  about  the  exami
\nnation\tneed  not  detain us.\tThe  Tabulators\t sent  their
\nremarks oil which investigation was made.  The Unfair  Means
\nCommittee and the Moderators gave their opinion.  These were
\nsufficient for taking action.  There was no need to wait for
\na  complaint,  not was a complaint  really  necessary.\t The
\nresults were withheld so that inquiries could be completed.’
\nIn the meantime the results of the other centres which\twere
\nnot under suspicion could be declared because in their\tcase
\nthere was no reason to withhold publication.
\nThe  contention\t that the Board alone and not  the  Chairman
\ncould, cancel the examinations need not detain us.  Under S.
\n6(2)  of the Bihar School Examinations Board Act, the  Board
\nconsiders,  moderates, determines and publishes the  results
\nof examinations.  It also admits candidates to examinations,
\ndisqualifies  them for any reason which it considers  to  be
\nadequate.   Under  -s. 9(3) of the Act in an  emergency\t the
\npowers\tof  the Chairman are co-terminus with those  of\t the
\nBoard and he can take action himself and later report it  to
\nthe  Board.  In this case action was taken by  the  Chairman
\nand  he\t reported it to the Board which fully  endorsed\t it.
\nTherefore the cancellation of the examina-\n<\/p>\n
 967<\/span><\/p>\n
tions at Hanswadih Centre must be treated as an order of the
\nBoard  and  cannot, therefore, be challenged on\t the  ground
\nthat it was incompetently made.\n<\/p>\n
This  brings us to the crux of the problem.  The High  Court
\ninterfered on the ground that natural justice and fair\tplay
\nwere not observed in this case.\t This was repeated to us  by
\nthe respondents in the appeal.\tA mention of fair play\tdoes
\nnot  come  very well from the respondents who  were  grossly
\nguilty\t of   breach  of  fair\tplay   themselves   at\t the
\nexaminations.\tApart from the reports of the  experts,\t the
\nresults\t speak\tfor themselves.\t At the\t other\tcentres\t the
\naverage\t of successful candidates was 50%.  At\tthis  centre
\nthe examinations had the following percentage\n<\/p>\n
1.   Mother Indian Language94\n<\/p>\n
2.   English70\n<\/p>\n
3.   Social Studies95\n<\/p>\n
4.   Everyday Science90\n<\/p>\n
5.   Elementary Mathematics100\n<\/p>\n
6.   Economics & Civics92\n<\/p>\n
7.   Elementary Physiology and Hygiene96\n<\/p>\n
8.   Geography….99\n<\/p>\n
9.   History88\n<\/p>\n
10.  Physics70\n<\/p>\n
11.  Chemistry100\n<\/p>\n
12.  Advance Mathematics99\n<\/p>\n
13.  Sanskrit100
\nThese  figures\tspeak for themselves.  However,\t to  satisfy
\nourselves  we ordered that some answer books be brought\t for
\nour inspection and many such were produced.  A comparison of
\nthe  answer books showed such a remarkable agreement in\t the
\nanswers\t that  no  doubt  was left in  our  minds  that\t the
\nstudents had assistance from an- outside source.   Therefore
\nthe  conclusion\t that  unfair  means  were…adopted  stands
\ncompletely vindicated.\n<\/p>\n
This is not a case of any particular individual who is being
\ncharged with adoption of unfair means but of the conduct  of
\nall the examinees or at least a vast majority of them -at  a
\nparticular centre.  If it is not a question of charging\t any
\none  individually  with\t unfair means  but  to\tcondemn\t the
\nexamination as ineffective for the purpose it was held, must
\nthe  Board  give  an opportunity to all\t the  candidates  to
\nrepresent their cases ? We think not.  It was not  necessary
\nfor  the Board to give an opportunity to the  candidates  if
\nthe examinations as a whole were being cancelled.  The Board
\nhad  not charged any one with unfair means so that he  could
\nclaim to defend himself.  The examination
\n9 68
\nwas  vitiated by adoption of unfair means on a\tmass  scale.
\nIn these circumstances it would be wrong to insist that\t the
\nBoard  must  hold  a detailed inquiry into  the\t matter\t and
\nexamine each individual case to satisfy itself which of\t the
\ncandidates had not adopted unfair means.  The examination as
\na whole had to go.\n<\/p>\n
Reliance  was placed upon Ghanshyam Das Gupta’s case(1),  to
\nwhich we referred earlier.  There the examination results of
\nthree  candidates were cancelled, and this Court  held\tthat
\nthey should have received an opportunity of explaining their
\nconduct.   It  was  also  said that  even,  if\tthe  inquiry
\ninvolved  a  large number of persons, the  Committee  should
\nframe  proper regulations for the conduct of such  inquiries
\nbut  not  deny the opportunity.\t We do not think  that\tthat
\ncase  has any application.  Surely it was not intended\tthat
\nwhere  the  examination\t as a whole  was  vitiated,  say  by
\nleakage\t of papers or by destruction of some of\t the  answer
\nbooks  or by discovery of unfair means practised on  a\tvast
\nscale  that  an inquiry would be made giving  a,  chance  to
\nevery.\tone appearing at that examination to have  his\tsay?
\nWhat  the  Court  intended  to lay  down  was  that  if\t any
\nparticular person was to be proceeded against, he must\thave
\na  proper chance to defend himself and this did not  obviate
\nthe  necessity\tof  giving an opportunity  even\t though\t the
\nnumber\tof persons proceeded against was large.\t  The  Court
\nwas  then not considering the right of an examining body  to
\ncancel\tits own examination when it was satisfied  that\t the
\nexamination  was  not  properly conducted  or  that  in\t the
\nconduct of the examination the majority of the examinees had
\nnot conducted themselves as they should have.  To make\tsuch
\ndecisions depend upon a full-fledged judicial inquiry  would
\nhold  up  the  functioning  of\tsuch  autonomous  bodies  as
\nUniversities  and  School Board.  While we do  not  wish  to
\nwhittle\t down the requirements of natural justice  and\tfair
\nplay  in cases where such requirement may be said to  arise,
\nwe  do\tnot  want that this Court should  be  understood  as
\nhaving,\t  stated   that\t  an  inquiry  with   a\t  right\t  to
\nrepresentation\tmust always precede in every  case,  however
\ndifferent.   The  universities\tare  responsible  for  their
\nstandards and the conduct of examinations.  The. essence  of
\nthe  examinations  is  that the worth  of  every  person  is
\nappraised without any assistance from an outside source.  If
\nat  a centre the whole body of students\t receive  assistance
\nand  manage to secure success in the neighbourhood  of\t100%
\nwhen  others  at  other centres are successful\tonly  at  an
\naverage\t of  50%, it is obvious that the university  or\t the
\nBoard  must  do something in the matter.  It cannot  hold  a
\ndetailed  quasi-judicial inquiry with a right to its  alumni
\nto  plead  and\tlead evidence etc. before  the\tresults\t are
\nwithheld or the examinations cancelled.\t If
\n[1] [1962] Supp. 3SC.R. 36.\n<\/p>\n
 969<\/span><\/p>\n
there is sufficient material on which it can be demonstrated
\nthat  the  university was right in its conclusion  that\t the
\nexaminations  ought to be cancelled then academic  standards
\nrequire\t that the university’s appreciation of\tthe  problem
\nmust  be  respected.  It would not do for the Court  to\t say
\nthat  he  should have examined all the\tcandidates  or\teven
\ntheir representatives with – a view to ascertaining  whether
\nthey  had  received  assistance or not.\t To  do\t this  would
\nencourage indiscipline if not also perjury.
\nWe  are satisfied that no principle of natural\tjustice\t was
\nviolated  in this case.\t The Board through its Chairman\t and
\nlater\titself\treached\t the  right  conclusion\t  that\t the
\nexaminations at this Centre had been vitiated by  practising
\nunfair\tmeans on a mass scale and the Board-had every  right
\nto cancel the examination and order that a fresh examination
\nbe  held.   There  was\tno need to  give  the  examinees  an
\nopportunity  of\t contesting  this  conclusion  because\t the
\nevidence  in the case was perfectly plain  and\ttransparent.
\nWe  therefore  set  aside the order of the  High  Court\t and
\nordered dismissal of the writ petition but made no order  as
\nto costs.\n<\/p>\n
V.P.S.\t\t\t\t\t\t      Appeal\nallowed.\n97 0\n\n\n\n<\/pre>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Bihar School Examination Board vs Subhas Chandra Sinha, & Ors on 10 March, 1970 Equivalent citations: 1970 AIR 1269, 1970 SCR (3) 963 Author: M Hidayatullah Bench: Hidayatullah, M. (Cj) PETITIONER: BIHAR SCHOOL EXAMINATION BOARD Vs. RESPONDENT: SUBHAS CHANDRA SINHA, & ORS. DATE OF JUDGMENT: 10\/03\/1970 BENCH: HIDAYATULLAH, M. (CJ) BENCH: […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-223384","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nBihar School Examination Board vs Subhas Chandra Sinha, & Ors on 10 March, 1970 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/bihar-school-examination-board-vs-subhas-chandra-sinha-ors-on-10-march-1970\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Bihar School Examination Board vs Subhas Chandra Sinha, & Ors on 10 March, 1970 - 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