Supreme Court of India
DISHA PANCHAL AND OTHERS versus UNION OF INDIA THE SECRETARY AND OTHERS on 13 June 2018
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SUPREME COURT REPORTS[2018] 5 S.C.R. 12
[2018] 5 S.C.R.
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DISHA PANCHAL AND OTHERS
v.
UNION OF INDIA THE SECRETARY AND OTHERS
(Writ Petition (Civil) No. 551 of 2018)
BJUNE 13, 2018
[UDAY UMESH LALIT AND DEEPAK GUPTA, JJ.]
Education/Educational Institutions – Admission to NationalLaw Universities – Online entrance test-Common Law AdmissionTest (CLAT) – Improper conduct of – Grievance of 4690 candidatesCthat loss of time as a result of inadequate facilities in conductingexaminations and not affording them single log in session withoutany interruption – On appeal, held: Purity of examination processwas not compromised so as to annul the entire process –Normalization formula would be the correct and appropriateDmethodology to compensate and take care of the interest of the 4690candidates and would also ensure that no prejudice is caused torest of the candidates – Normalization formula proceeds on the basisof answering efficiency or capacity of a candidate to answerquestions in given time and then applies his rate of success as aparameter – Thus, the normalization formula is accepted and theEoutright cancellation of the entire test is rejected – Exercise ofadopting and applying the normalization formula and revising thescores of 4690 candidates to be undertaken and completed withinthe stipulated period – Furthermore, the examination was notconducted satisfactorily – There was complete inadequacy –FIssuance of direction to the government to appoint a Committee tolook into the matter and take appropriate remedial measures.
Disposing of the petitions, the Court
HELD: 1.1 The basic grievance raised by the candidatespertains to loss of time as a result of deficiency on part of theGexamination conducting body in not ensuring adequate facilitiesand not affording them single log in session without anyinterruption. The idea so projected is pointing towards loss oftime and inconvenience and not suggesting that the purity ofexamination process was in any way compromised so as to annulHthe entire process. Any outright cancellation would visit tremendous inconvenience and hardship upon rest of thecandidates. If the interest of those candidates who suffered lossof time could otherwise be compensated, there is no reason thatthe entire admission test be cancelled or annulled. [Para 8][22-G-H; 23-A]
1.2 In the Chart, all the details including time availed, timelost, number of questions attempted, number of questionscorrectly answered, number of questions wrongly answered andthe answering efficiency of the candidates are tabulated. The nextcolumns give the notional figure as to how many questions hewould have answered if there was no time loss and how manyquestions he would have rightly answered. These notional figuresgive statistically correct and appropriate formula to compensatefor the loss of time. The figures gives the chart against thecandidates showing that applying the normalization formula, wherethe candidate would be entitled to be placed at. [Para 9][24-A-C]
1.3 Since all the details regarding log in and log out timesare available in respect of each of those 4690 candidates, it ispossible to arrive at revised score applying such normalizationformula in respect of said 4690 candidates. The normalizationformula so suggested, in the circumstances, would be the bestpossible way to compensate and take care of the interest of those4690 candidates. At the same time, it would also ensure that noprejudice is caused to rest of the candidates. The normalizationformula proceeds on the basis of answering efficiency or capacityof a candidate to answer questions in given time and then applieshis rate of success as a parameter. Normally, a candidate wouldfirst answer those questions, whose answers he is well aware ofand leave out rest to be answered in the end. His success rate inthe former part would certainly be greater, as compared to thelatter. Since he would be given benefit at the same success rate,there would be no prejudice. It is true that repeated interruptionswould cause mental stress and upset him. But that aspect as afactor is difficult to be translated in a quantifiable parameter. Giventhe circumstances, the normalization formula appears to be thecorrect and appropriate methodology. Therefore, the formula sosuggested is accepted and the contention of outright cancellationof the entire test is rejected. [Para 10][24-D-H; 25-A]
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A1.4 Having considered the entirety of the matter, thefollowing directions are given:
A). The exercise of applying normalization formula andrevising the scores of 4690 candidates shall be completed by15.06.2018. Respondent Nos.2 and 3 through its Convenor –ViceBChancellor, National University would undertake the entireexercise and complete it by 15.06.2018.
B). Upon completion of said exercise, the revised scoresof 4690 candidates would be published by respondents 2 and 3on the official website on 16.06.2018.
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C). Based on such revised scores the merit list would berearranged in terms of the suggestion given by the Committee.The revised position of the concerned candidate would beindicated by rank Nos.51A-51B.
D). The first round of counseling which began on 10.06.2018Dwould go on without any impediment and if any candidate isallocated a seat, such allocation will not in any way stand adverselyaltered as a result of revised position granted to any of thecandidates from the body of 4690 candidates.
E). If any candidate from the body of 4690 candidates isEotherwise entitled, that is to say even without the benefit ofrevised score, to be allocated any seat, it goes without sayingthat such allocation would not in any way stand adversely affected.
F). In the second round of counseling the rank/merit list soprepared in terms of these directions would be the governingFlist and the seats in second and subsequent rounds of counselingwould be allocated on the basis of the list so revised in pursuanceof these directions.
G). If a candidate, as a result of revised rank list beingoperative in second and subsequent round of counseling wantsGto secure admission in any other college of his or her choicegoing by his or her revised ranking, he/she would be allowed todo so without incurring any disadvantage. In such cases, the feesif deposited in the first college shall be given due credit againstthe admission in the second college which the candidate may optfor as a result of revised ranking. [Para 12][25-C-H; 26-A-C]
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1.5 The matter is dealt with only from the stand point ofhow best to compensate the candidates who lost valuable timewhile undergoing test. The way the examination was conductedis not satisfactory. The body which was given the task ofconducting the examination was duty bound to ensure facilitiesof uninterrupted UPS and generator facility. The record indicatescomplete inadequacy on that point. Thus, the Union of India inthe Ministry of Human Resources and Development is directedto appoint a Committee to look into the matter and takeappropriate remedial measures including penal action, if any,against the body which was entrusted with the task. TheCommittee so constituted shall also look into the aspect of havingcompletely satisfactory arrangements in future so that no suchinstances are repeated or reoccur in coming years. It is observedthat the idea of entrusting the task of monitoring the conduct ofentire examination to different Law Universities every year alsoneeds to be re-visited. The agreement with the examinationconducting body, which was placed on record indicates that asagainst the amount made over to such examination conductingbody, the fees charged from the candidates are far in excess. TheCommittee would bestow consideration to all these aspects afterhaving inputs from such sources as it may deem appropriateincluding Bar Council of India and make a detailed report to thisCourt within the stipulate period. The High Courts are requestedto dispose of the pending matters raising challenge in respect ofCLAT 2018, in the light of the directions. [Paras 13, 14][26-D-H]
CIVIL ORIGINAL JURISDICTION: Writ Petition (Civil) No.551 of 2018.
Under Article 32 of the Constitution of India.
WITH
Harvinder Chowdhury, Ramesh Chand, Dr. Nishesh Sharma, Ms.Meera Patel, Anil Kumar Singh, Ketan Nehra, Anand Shankar Jha, ArpitGupta, Siddharth Tiwari, Zoheb Hossain, Rajendra Dangwal, Ms. RashmiSinghania, Maninder Singh, Shalinder Saini, Sanjay K. Pathak, AmarjeetSingh, Gurmeet Singh Makker, A. Karthik, Gaurav Bahl, Sudhanshu Palo,Advs. for the appearing parties.
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AThe Judgment of the Court was delivered by UDAY UMESH LALIT, J. 1. These petitions highlight improperconduct of Common Law Admission Test (CLAT) 2018 by RespondentNos.2 and 3, which is a single window online entrance test for admissionto 19 prestigious National Law Universities in the country. The petitionersBhad appeared for said CLAT and had faced various difficulties, whichaccording to them, were occasioned as a result of mismanagement byrespondent Nos.2 and 3. Some of the difficulties that were experiencedby the petitioners and other candidates were:
A. Questions of the examination did not appear on the screen atCthe start, and were intermittently disappearing and re-appearing.
B. The options to move to the next question, etc. stopped workingintermittently.
C. Blank screens or frozen screens and software crashes.
DD. Invigilators were incompetent and unhelpful – in being unableto help resolve glitches and in terms of their rudeness, whenapprised of the existence of glitches.
E. Computers were dysfunctional and rebooting them did not help.
Resultantly, the effective time available to the candidates was farElesser than the allotted time, which in turn caused great prejudice to thecandidates.
2. In addition to the petitions filed in this Court, some candidatesalso approached various High Courts, where the petitions are still pending.By order dated 24.05.2018 this Court had said, “as the entire issue inFreference to CLAT Examination – 2018 is the subject matter in thepresent proceedings, it is appropriate that no High Court shall proceedwith the hearing of pending proceedings on the subject matter till furtherorders.”
3. On 25.05.2018 following order was passed by this Court:
G“In deference to the observations made by the Court during thecourse of hearing yesterday, Respondent Nos.2 and 3 havegraciously agreed to constitute a Grievance Redressal Committeeconsisting of a retired Judge of the Kerala High Court, Mr. JusticeM.R. Hariharan Nair, Dr. Santhosh Kumar G., Professor and Head, H
Department of Computer Science, Cochin University of Scienceand Technology. The Committee will be chaired by Mr. JusticeM.R. Hariharan Nair who will examine every singularrepresentation/complaint received online till now and any furtherrepresentation/complaint received till 7.00 p.m. of Sunday, 27[th]May,2018 and after due analysis, appropriate decision on case to casebasis will be taken by the Committee.
In the first phase, the representations/complaints already receivedand of all the writ petitioners before this Court as well as differentHigh Courts may be scrutinized and appropriate report/recommendation/ decision thereon be recorded by the appropriateauthority before 29[th ]May, 2018 to be produced before the Courton 30[th] May, 2018.
In the second phase, new/fresh representation/complaints receivedonline upto 7.00 p.m. of Sunday, 27[th] May, 2018 be taken up forconsideration and, if possible, the scrutiny thereof be completedon the same lines as indicated above up to 29th May, 2018 andstatus report in that behalf be filed before the Court on 30[th] May,2018.
Learned counsel for Respondent Nos.2 and 3 submits that assoon as fresh/new representations/complaints are received online,attempt will be made to acknowledge the same contemporaneouslyas far as possible.
We appreciate the fair stand taken by learned counsel forRespondent Nos.2 and 3 to offer dispensation of this nature withinsuch a short time.
Learned counsel for Respondent Nos.2 and 3 submit that adedicated email account will be created for this purpose of whichpublicity will be given on the official website of CLAT and will benotified on the official website very shortly within two hours fromnow.
We make it clear that this order will also enure to the benefit ofthe writ petitioners who have filed writ petition in different HighCourts.
Interim stay regarding proceedings pending before different HighCourts will continue to operate till the next date of hearing.
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AList the matters on 30th May, 2018.”
4. The Grievance Redressal Committee so constituted, has sincethen filed a comprehensive report enclosing certain annexures. Copiesof the report as well as annexures were directed to be given to thelearned counsel appearing for the parties to enable them to assist thisBCourt. Paragraphs 4, 12 and 14 of the Report are as under:- “4. The number of candidate writ petitioners as on 30-05-2018:25 (Sl. Nos. 1-25 of Annexure – I of the first Report dated 29-05-2018)
Number of complaints received up to the hearing of the case; i.e.,C11.30 hrs on 25-05-2018 - 2676
Number of complaints received between 11.30 am and 7 p.m. on25-05-2018 - 115
Number of complaints received in the new e- mail id betweenD5.50 p.m. on 25-05-18 to 7.00 p.m. on 27-05-2018 - 5677.
12. The team of service providers representing the Sify providedthe Committee with display of the Audit Report and all Supporting dataavailable at the central server of the company. The names of theseofficers are in Annexure -II (already submitted along with the Reportdated 29-05-2018). In certain cases the Committee felt that the explanationEof the Service Provider regarding alleged lapses was essential. The detailsso obtained are in Annexure -III (already submitted along with the Reportdated 29-05-2018).
14. On a perusal of the various complaints raised by the candidates,the Committee felt that they broadly fall under one or more of the followingFcategories:
1. Frequent login failures.
2. Change of machines / mouse and disruptions.
3. Questions not visible in full or in part.
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4. Registered answers disappeared.
5. Heat and unfavourable environment.
6. Commotion and distraction.
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DISHA PANCHAL v. UNION OF INDIA THE SECRETARY[UDAY UMESH LALIT, J.]
7. Time extension not effective as there was no re log in.
8. Undue time extension was given to some.
9. Deliberate cheating by closure of browser.
10. Power failure and absence of UPS needing multiple log insand distraction of concentration.
11. Pre-examination preparation sessions were ineffective; veryoften machines had to be changed and distracted.
12. Invigilators unhelpful.”
5. The matter was dealt with by the Committee in the light of theaudit report and the data made available relating to 4690 candidates.The Committee then considered the matter under the heading “Detailsof appraisal” and made certain suggestions as under:
“A. Scrutiny of the data relating to 4690 candidates shows thatsome of the candidates got only lesser time than what is due tothem for appearance in the examination. These are categorizedas follows:
1. candidate who got deficiency of less than one minute: 70
2. candidate who got deficiency of less than two minute: 140
3. candidate who got deficiency of more than one minute: 94
Thus the total number of candidates who got time marginallydeficient is 210 and including those who lost more than two minutes,it is 304.
Similarly, the data analysis shows that –
i. 2276 of them had a single log in session right fromcommencement of the examination till its culmination.
ii. 1899 of the applicants needed multiple log in sessions with noresponse in the first session. This comes under three subcategories viz.
(1) Due extension of time was not given in 892 cases involvingmultiple sessions, out of which 623 candidates got effectivetime of 2 hours for completing the examination.
(2) Time extension given and availed: 558
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A(3) Time extension given and not availed: 449
iii. Multiple logins with response in first session: 515
14A*[1]. Clause 7 and 19 of Annexure XI, read with clause l and m(iii) of Annexure xii cast a duty on Sify Technologies to ensurethat UPS and Generator facilities were provided so as to ensureBfacility of uninterrupted activity for the candidate. The lapse inthe matter appears to be the main cause which led to need forfrequent re logins on the part of the candidate.
15. The CLAT of 2018 was fraught with various imperfections.The major defects found are categorized as follows:
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i. The majority of complaints relate to failure of initial log in.Multiple log in appears to have affected the performance of thesystem. Software and hardware efficiency will depend uponserver capacity and efficacy. Under Cl.8, page 8, of Ann.XII,the Service Provider was duty bound to provide trouble-freesoftware. Common defect of initial log in failure must havearisen from the hardware, software or network deficiencies.
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ii. Conduct of a test of this magnitude without providing efficientsoftware and computers to the candidates has resulted inavoidable interruptions in answering questions.
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iii. Infrastructural defects like want of/failure of the airconditioning systems which stood in the way of the bestperformance of students in many centres in the examinationconducted at the peak of summer.
iv. Power failure which affected many centres has resulted inloss of time and disturbance to the concentration of mind requiredfor a smooth performance in a competitive test.
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v. Failure of invigilators to facilitate re-login which is essentialfor availing the benefit of extended time granted to compensatefor lost time arising from power failure, system hanging, etc.
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vi. Failure to grant extended time even in cases where the firstlog in attempt failed or in the subsequent attempt/s the timeobtained is lower than what is prescribed, though such reduction was only marginal.
*[1] This para, also marked as para 14 in the report has been renumbered by us as paraH14A
vii. To redress the genuine grievances projected, two coursesappear to be open. They are:
1. The cancellation of the entire test and re-conduct thereof.The Committee does not suggest the same considering themagnitude of the requirements and the need to ensure smootheducation of the successful candidates during the currentacademic year.
2. A method to compensate the students with some marksconsidering the lost time for those who underwent the need tore long in more than once; loss of opportunity to get extendedtime or to avail the same even after being found eligible. Thiscommittee, as it stands, now, has no capacity to suggest acompensatory formula. Either it has to be expanded includinga statistician of competence or in the alternative, consider aformula or other compensatory solution suggested at the Bar,if any.
3. When the list is redrawn after providing compensation asabove, it has to be ensured that the rank of candidates in theexisting list are not affected. That is to say, in case one morecandidates with the same mark acquires eligibility for the reasonthat another person with the same mark has got into the eligibilitylist as per the existing rank, (say 51), such candidates may beadded with Rank Nos. 51A, 51B, etc. and for accommodatingthe number of such additional entrants an equal number ofsupernumerary seats may be created on an ad hoc basis. Thiswill ensure that no heart burn is caused to candidates whohave already ensured their berth in the rank list.
4. No relief is suggested on the ground of errors in framing ofquestions or in the matter of fixing the answer key. This is sobecause a Committee of four vice chancellors has alreadyreviewed the questions and answers thread bare and found, inits meeting held on 13.05.2018 that inaccuracy exists only inthe case of Qn. No. 83(393) and proceeded to cancel thatQuestion and accordingly directed evaluation of the papertreating the total marks only as 199 instead of 200 as originallyplanned. With regard to Qn.No.153 (463) which originallycarried a wrong answer key, it was decided by that VC
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22SUPREME COURT REPORTS
ACommittee to correct the answer key and to upload thecorrected key in CLAT-2018 web site. The result declared isin accordance with the above changes. The controversy overinaccuracy of questions and key may end there.”
6. The audit report placed along with the Report sets out allBrelevant details as to that how the candidates had navigated from onequestion to the other and the exact Log in and Log out time. The auditreport also gives details about actual time made available to each candidateincluding extension of time, wherever it was granted/availed. Accordingto the Committee, 2276 candidates had single log in session right fromthe commencement of the examination while 1899 candidates requiredCmultiple log in sessions, the details of which are given in the extracthereinabove. The Committee also touched upon the issue as to how thestudents could be compensated. The facts indicate that out of 54464candidates who took the examination at 250 centres, 4690 candidateshad raised grievances within the time stipulated by this Court. The dataDrelating to such 4690 candidates has been catalogued by the Committee.
7. We have heard Mr. Sanjay R. Hegde, learned Senior Advocatefor the Petitioners, Mr. Maninder Singh, Additional Solicitor General forUnion of India, Mr. V. Giri, learned Senior Advocate for Respondents 2and 3 and all other learned advocates who appeared for variousEInterveners and petitioners in connected matters. Two questions arisefor our consideration:
(a) Whether the entire test needs to be cancelled and a fresh testis required to be ordered; (b) If the entire test is not to be cancelled, what methodology canFbe adopted to compensate the students who had lost time andwere put to prejudice.
8. The basic grievance raised by the candidates pertains to loss oftime as a result of deficiency on part of the examination conductingbody in not ensuring adequate facilities and not affording them single logGin session without any interruption. The idea so projected is pointingtowards loss of time and inconvenience and not suggesting that the purityof examination process was in any way compromised so as to annul theentire process. Any outright cancellation would visit tremendousinconvenience and hardship upon rest of the candidates. If the interestof those candidates who suffered loss of time could otherwise beH
compensated, there is no reason that the entire admission test becancelled or annulled. We, therefore, invited learned counsel to addressthe Court on what could be the possible solution to take care of theinterest of those 4690 candidates. Mr. V. Giri, learned Senior Advocateplaced before us the following Chart in relation to four petitioners byway of illustration.
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A9. In the Chart, all the details including time availed, time lost,number of questions attempted, number of questions correctly answered,number of questions wrongly answered and the answering efficiency ofthe candidates are tabulated. For instance, Animesh Shukla had lost 553seconds i.e. roughly over nine minutes. Out of 200 questions, he hadcorrectly answered 125 questions while his answers in respect of 47Bquestions were found to be wrong. The score that he secured was 113.25.Considering the number of questions attempted, the answering efficiencywas found to be 38.65 seconds per question. The next columns give thenotional figure as to how many questions he would have answered ifthere was no time loss and how many questions he would have rightlyCanswered. These notional figures give us statistically correct andappropriate formula to compensate for the loss of time. The figuresgiven in the chart against this candidate show that applying thenormalization formula, the candidate would be entitled to be placed at ascore of 122.25 as against 113.35.D10. Since all the details regarding log in and log out times areavailable in respect of each of those 4690 candidates, it is possible toarrive at revised score applying such normalization formula in respect ofsaid 4690 candidates. We repeatedly asked the learned advocates forthe petitioners and intervenors whether they could suggest any alternatemechanism or point out any infirmity or fault in normalization formula soEplaced by Mr. V. Giri, learned Senior Advocate but no counsel couldsuggest any alternative or point out any infirmity. According to us, thenormalization formula so suggested, in the circumstances, would be thebest possible way to compensate and take care of the interest of those4690 candidates. At the same time, it would also ensure that no prejudice Fis caused to rest of the candidates. The normalization formula proceedson the basis of answering efficiency or capacity of a candidate to answerquestions in given time and then applies his rate of success as a parameter.Normally, a candidate would first answer those questions, whose answershe is well aware of and leave out rest to be answered in the end. His success rate in the former part would certainly be greater, as comparedGto the latter. Since he would be given benefit at the same success rate,there would be no prejudice. It is true that repeated interruptions wouldcause mental stress and upset him. But that aspect as a factor is difficultto be translated in a quantifiable parameter. Given the circumstances,the normalization formula appears to be the correct and appropriateH
methodology. We, therefore, accept the formula so suggested and rejectthe contention of outright cancellation of the entire test.
11. Mr. V. Giri, learned Senior Advocate also submitted that by15[th] June, 2018 the entire exercise of adopting and applying thenormalization formula and arriving at a revised score in respect of 4690candidates could be undertaken and completed. We record saidsubmission and proceed on that premise. We have also been given tounderstand that the first round of counseling has already begun.
12. Having considered the entirety of the matter, we give followingdirections:
A). The exercise of applying normalization formula as suggestedby Mr. V. Giri, learned Senior Advocate and revising the scoresof 4690 candidates shall be completed by 15.06.2018. RespondentNos.2 and 3 namely the National University of Advance LegalStudies, Kochi and Core Committee-Common Law Admission Test2018 through its Convenor –Vice Chancellor, National Universityof Advance Legal Studies, Kochi shall undertake the entireexercise and complete it by 15.06.2018.
B). Upon completion of said exercise, the revised scores of 4690candidates will be published by respondents 2 and 3 on the officialwebsite on 16.06.2018.
C). Based on such revised scores the merit list will be rearrangedin terms of Para 3 of the suggestion given by the Committee. Inother words, the revised position of the concerned candidate willbe indicated by rank Nos.51A-51B as illustrated by theCommittee.
D). The first round of counseling which began on 10.06.2018 shallgo on without any impediment and if any candidate is allocated aseat, such allocation will not in any way stand adversely alteredas a result of revised position granted to any of the candidatesfrom the body of 4690 candidates.
E). If any candidate from the body of 4690 candidates is otherwiseentitled, that is to say even without the benefit of revised score, tobe allocated any seat, it goes without saying that such allocationwill not in any way stand adversely affected.
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SUPREME COURT REPORTS
AF). In the second round of counseling the rank/merit list so preparedin terms of these directions shall be the governing list and theseats in second and subsequent rounds of counseling will beallocated on the basis of the list so revised in pursuance of thesedirections.
BG). If a candidate, as a result of revised rank list being operativein second and subsequent round of counseling wants to secureadmission in any other college of his or her choice going by his orher revised ranking, he/she shall be allowed to do so withoutincurring any disadvantage. In such cases, the fees if deposited inthe first college shall be given due credit against the admission inCthe second college which the candidate may opt for as a result ofrevised ranking.
13. We have dealt with the matter only from the stand point ofhow best to compensate the candidates who lost valuable time whileundergoing test. We must record that we are not at all satisfied with theDway the examination was conducted. The body which was given thetask of conducting the examination was duty bound to ensure facilitiesof uninterrupted UPS and generator facility. The record indicatescomplete inadequacy on that point. We therefore direct Union of Indiain the Ministry of Human Resources and Development to appoint aECommittee to look into the matter and take appropriate remedialmeasures including penal action, if any, against the body which wasentrusted with the task. The committee so constituted shall also lookinto the aspect of having completely satisfactory arrangements in futureso that no such instances are repeated or reoccur in coming years. Wemust also observe that the idea of entrusting the task of monitoring theFconduct of entire examination to different Law Universities every yearalso needs to be re-visited. The agreement with the examinationconducting body, which was placed on record indicates that as againstthe amount made over to such examination conducting body, the feescharged from the candidates are far in excess. The committee shallGbestow consideration to all these aspects after having inputs from suchsources as it may deem appropriate including Bar Council of India andmake a detailed report to this Court within three months from today.
14. Since we have dealt with the matter and passed comprehensivedirections, we request the High Courts to dispose of the pending mattersHraising challenge in respect of CLAT 2018, in the light of our directions.
DISHA PANCHAL v. UNION OF INDIA THE SECRETARY[UDAY UMESH LALIT, J.]
15. All the petitions are thus disposed of. We record our sincereappreciation for the efforts put in by the members of the GrievanceRedressal Committee and for the assistance rendered by all the learnedcounsel.
Nidhi Jain
Petitions disposed of.
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