Rajasthan High Court Upholds Accommodation For 'Karwa Chauth' Granted To Female Candidates In 2021 Patwari Recruitment Exam

Upholding the 2021 Patwari Direct Recruitment Examination result, the Rajasthan High Court said that the normalization process followed was as per law and the accommodation granted to female candidates to appear for the exam one day prior on account of Karwa Chauth does not violate Article 14 or 16 of the Constitution. 

The division bench of Justice Pushpendra Singh Bhati and Justice Chandra Prakash Shrimali was hearing a batch of petitions challenging the final selection list on the ground that normalization methodology adopted by the Examination Board was applied ex-post facto and was also in contravention with law.

The Exam was held in October 2021, and was conducted in 4 sessions over 2 days. Out of the 2 days, the next day was supposed to be observed as the “Karwa Chauth”. As the examination saw participation of over 5 Lakh women, in deference to Festival of 'Karva Chauth' observed on 24.10.2021, a significant proportion of female candidates opted, and were duly accommodated, to appear in the exam during the two shifts conducted on 23.10.2021.

Upholding the single judge's order which had agreed with the normalization process the high court said:

"Thus, the learned Single Judge has gone with the experts who have supported the process of normalization as an equalizing impact which was neither in contradiction to the Rules of 2019 nor to any other prevailing law. The learned Single Judge has rightly arrived at a conclusion that the experts were not under any kind of cloud and the normalization was required to be taken place. The examination conducted on a day prior to Karwa Chauth was an accommodation which has been widely done on a festival which is more participative for the female candidates, and thus, there is no wrong in having most of the female candidates on the shifts on 23.10.2021, whereas the Karwa Chauth on 24.10.2021". 

The syllabus and subjects across all 4 sessions were the same, but the question papers were different. To ensure equity in preparation of results, a committee of experts was constituted by the Board. The committee suggested application of the widely recognized normalization formula by V. Natarajan and K. Gunasekaran based on which the results were published.

The result was challenged firstly on the ground that instead of the standard equal percentile formula of normalization, a different mode of normalization was applied. Secondly, it was argued that no disclosure of the formula of normalization was made in the Rules and Scheme of the Examination which were provided at the initial stage.

It was submitted that since there was no provision in law to alter, modify or change the marks on the pretex of normalization, the same could not have been done.

On the contrary, the State argued that the normalization formula was applied uniformly to all the candidates across all 4 shifts and the process was designed to precisely neutralize the differences in the difficulty levels, based on recommendations of the Expert Committee. Since appointments were already made, quashing would be contrary to public interest.

After hearing the contentions, the Court agreed with the arguments put forth on behalf of the State and perused the considerations taken into account by the Single Judge bench to uphold the legality of the results.

Hence, it was held that the experts had rightly concluded the finality of normalization formula to give equal strength to all candidates. It said,

"This Court thus holds that the experts opinion has rightly culminated into finality with the formula for normalization giving an equal strength to all the candidates who participated in terms of chances of success. This Court concludes that a similar playing field for the fourth shifts has been dealt with. This Court finds that the examination was conducted in four batches and the method of normalization method was uniformly applied across as per the parameters settled by the Expert Committee, and thus, the process of examination was sterling worth. The report of the Expert Committee is not under challenge. The merit list has resulted into filling of the posts"

The court said that the expert committee was not under any kind of cloud and "normalization/equalization/scaling" are the techniques which are statistical in nature and used to dismantle the disparity between the participative recruitment candidates.

It said that this technique is adopted to check the impact of any disadvantage or extraordinary advantage being extended to only one set of participants on account of their question papers or shifts.

Accordingly, the appeals were dismissed.

Title: Riteesh Kumar Jyotishi & Ors. v State of Rajasthan, and other connected matters

Citation: 2025 LiveLaw (Raj) 262

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