Madhya Pradesh High Court: In a batch of writ petitions challenging the difficulties faced by the students due to power outage in 12 examination centres in Madhya Pradesh during the NEET Undergraduate (UG) Examination, 2025 (‘the exam’), the Single Judge Bench of Subodh Abhyankar, J., allowed the petitions, holding that the petitioner(s) had made out a case for interference under Article 14 as they, without there being any fault on their part, were put into a disadvantageous position due to power outage. Accordingly, the Court directed the National Testing Agency (‘NTA’) to expeditiously conduct a re-test and evaluate the ranks of the petitioners according to the re-test scores. Accordingly, the counselling was also delayed to account for the re-test scores.
Background
The petitioner, an aspiring doctor, took the exam conducted by the NTA on 04-05-2025. Due to a severe thunderstorm in Madhya Pradesh, there was a power outage in the exam centre, which forced the petitioner to give the exam in the dark, thereby affecting her performance in the examination. Additionally, no extra time was given for the time lost.
Analysis
At the outset, the Court agreed that due to weather, there was a power disruption ranging from 10 to 80 minutes during the exam hours at 12 exam centres as per the report submitted by the Collectorate, Indore. However, the said report also mentioned that there was no disruption in the examination. Along with the report, Principals of various centres had also certified that there was sufficient natural light available in the rooms. The Court also found that the Statistical Analysis report submitted by the NTA (‘NTA report’) concluded that there was no evidence to suggest that the power outage had any significant adverse impact on candidates’ performance as measured by the number of questions attempted.
Regarding the video clips filed by the petitioner wherein the authorities admitted the power disruptions, the Court stated that it was unclear from which centres the clips had been obtained, and it was not established that the clips were of the same date. However, the Collector’s statement to the media admitting the unprecedented weather could certainly be relied upon in the absence of rebuttal.
The Court also found that as per the guidelines provided to the examination centres, one of the conditions was that the centres must have CCTV installed, and admittedly, the respondents had not presented even a single CCTV footage of the classes where exams were being conducted, and there was a power outage.
To examine the condition faced by the students, the Court experimented by closing all lights to see how much natural light would enter the courtroom, which had four big glass windows and two glass doors. After conducting this experiment, the Court noted that there was some natural dim light which entered the courtroom, however such windows may or may not have been available in the exam centres, and even if available, it was unknown whether such windows would allow the sufficient natural light to get into the room, especially in harsher weather.
Regarding the NTA report, the Court noted that it did not consider the data along with the adverse weather conditions, which adversely affected the performance of the petitioner. The Court opined that such a report, which did not consider the human emotions prevailing at that time, could not be blindly accepted on its face value. The Court remarked,
“It must be remembered that the exam was only of three hours, in which, even for ten minutes, if a student faces a difficulty in reading and writing due to power outage, the same has the effect of rattling ones mental condition, and sufficient to disturb his or her composure and focus for the remaining time.”
Regarding the re-examination, the Court referred to Vanshika Yadav v. Union of India, (2024) 9 SCC 743, and stated that if the re-examination was directed for only those students who had approached the Court before release of provisional answer key on 03-06-2025, then their rank could be directed to be based solely on their score in the re-test.
Regarding the contention that some petitioners gave the exam from the centres that did not suffer any power outage, the Court stated that it was difficult to accept this contention prima facie without any cogent documents to support it. In this regard, the Court also took note of the reports submitted by the center observers, where it was stated that there was a power outage without any power backup.
Furthermore, the Court rejected the contention that it was not pitch dark in the classrooms stating that it was not necessary to have the zero visibility to be unable to read or write because even if the classrooms had some light, but not the sufficient enough for them to read and write, their claim could not be rejected prima facie.
As far as the preparation of the paper of the same level of difficulty was concerned, the Court stated that NTA, with its vast resources, would be able to come up with a solution. The Court also expressed that it would be surprised if the NTA had not prepared any other set of papers as a backup to meet any contingency. The Court added that indeed there could not be an at par evaluation of the performance of the candidates who have given exams containing different sets of question papers.
Given the aforesaid, the Court held that the petitioner(s) had made out a case for interference under Article 14 as they, without there being any fault on their part, were put into a disadvantageous position due to power outage, which did not prevail in the other examination centres or even in the same centre where some of the students were sitting at favorable spots having sufficient natural light.
Accordingly, the petition was allowed, and the NTA was directed to conduct the examination expeditiously and declare the results. The Court clarified that the petitioner(s) rank(s) shall be based solely on their scores in the re-test. Furthermore, the counselling shall be subject to the result of the petitioner(s) in the re-test.
Further, the Court stated that this order shall apply to those petitioners,
- who filed their petitions before 03-06-2025,
- who appeared in the exam from the Ujjain centre, and
-
whose results have been declared, but the petitions were filed before 03-06-2025,
regardless of whether any interim order was passed in their favour or not.
The Court added that those petitioners who filed their petitions on or after the release of the provisional answer key would not be entitled to reexamination, as they took a chance by not filing their petitions in time and waited for the declaration of results. If they were concerned about their performance due to the power outage, they were required to file their petitions before the release of the provisional answer key.
[Laxmi Devi v. National Testing Agency, 2025 SCC OnLine MP 4690, decided on 23-06-2025]
Advocates who appeared in this case:
For the petitioners: Mradul Bhatnagar, Akash Sharma, N.S. Bhati, Nitin Vyas, Amit Raj, Rajnish Yadav, Aman Mourya, Prakhar Karpe, Chinmay Mehta, Dharmedra Thakur, Atul Bukhariya, Madhusudan Dwivedi, Sapna Patwa, Ajay Ukas, Akash Sharma, Kirti Patwardhan, Jaswant Singh Chouhan, Rahul Yadav, Deesha Goyal, Ashish Choubey, Vikas Jain and Arjun Pathak
For the respondents: Solicitor General of India Tushar Mehta, Senior Advocate Rupesh Kumar, Deputy Solicitor General of India Romesh Dave —assisted by Ms. Pankhuri Shrivastava, Ms. Diksha Paliwal, Ms. Bhumika Dwivedi and Shri Atharava Dave
