Supreme Court Upholds Normalization Process in Police Recruitment — Equi-Percentile Method Valid for Multi-Session Exams. Standardized Equi-Percentile Method for Normalization of Marks Across Different Sessions of Written Examination Held Permissible Under Uttar Pradesh Sub Inspector and Inspector (Police) Service Rules, 2015.

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Case Note & Summary

The case pertains to the recruitment process for 2400 posts of Sub-Inspector of Police, 210 posts of Platoon Commander (PAC), and 97 posts of Fire Officer (Grade-II) in Uttar Pradesh Police, along with 600 posts of Sub-Inspector (Nagrik Police) for female candidates. The Uttar Pradesh Police Recruitment and Promotion Board issued notifications inviting online applications, and 6,30,926 candidates applied. Due to the large number of candidates, the written examination was conducted in 29 different sessions between 12th and 23rd December 2017, with different question papers for each session. The Board adopted the Standardized Equi-percentile method for normalization of marks, as used in MAH-MBA/MMS CET 2015, to equate scores across sessions. After the examination, 11,741 candidates were called for the Physical Standards Test and Physical Efficiency Test, comprising 5,461 candidates who secured more than 50% raw marks and 5,713 candidates who secured more than 50% marks only after normalization. Some candidates who had secured more than 50% raw marks challenged the inclusion of candidates who qualified only through normalization, filing Writ Petition No.23733 of 2018 in the Allahabad High Court. The High Court upheld the normalization process. The Supreme Court, in these appeals, considered the validity of the normalization method. The court noted that the notification did not specify that only raw marks would be considered and that normalization was a standard practice for multi-session examinations to ensure fairness. The court held that the Board's decision to consider candidates who secured 50% marks either in raw marks or after normalization was permissible and did not violate any rules. The appeals were dismissed, affirming the High Court's judgment.

Headnote

A) Service Law - Recruitment - Normalization of Marks - Standardized Equi-percentile Method - Uttar Pradesh Sub Inspector and Inspector (Police) Service (1st Amendment) Rules, 2015 - The court considered the validity of the normalization process adopted for a multi-session online written examination for recruitment to the posts of Sub-Inspector of Police, Platoon Commander (PAC), and Fire Officer (Grade-II) in Uttar Pradesh Police. The Board used the Standardized Equi-percentile method to equate scores across 29 different sessions with different question papers. The court held that the normalization process was permissible and that candidates who secured 50% marks after normalization were eligible for further stages of selection. The court found no illegality in the procedure and dismissed the appeals challenging the High Court's judgment upholding the normalization. (Paras 1-10)

B) Service Law - Recruitment - Eligibility Criteria - Minimum Qualifying Marks - Uttar Pradesh Sub Inspector and Inspector (Police) Service (1st Amendment) Rules, 2015 - The notification required candidates to score a minimum of 50% marks in the written examination. The Board interpreted this as 50% marks either in raw marks or after normalization. The court upheld this interpretation, noting that the notification did not specify that only raw marks would be considered and that normalization was a recognized method to ensure fairness across different sessions. (Paras 2-5)

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Issue of Consideration

Whether the process of normalization of marks by the Standardized Equi-percentile method adopted by the Uttar Pradesh Police Recruitment and Promotion Board for the written examination held in multiple sessions was valid and whether candidates who secured more than 50% marks only after normalization could be considered qualified.

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Final Decision

Appeals dismissed. The Supreme Court upheld the High Court's judgment and the normalization process adopted by the Uttar Pradesh Police Recruitment and Promotion Board.

Law Points

  • Normalization of marks
  • Equi-percentile method
  • Multi-session examination
  • Recruitment procedure
  • Police service rules
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Case Details

2022 Lawtext (SC) (1) 96

CIVIL APPEAL NO. 228 OF 2022 (@ Special Leave Petition (Civil) No.29972 of 2019)  WITH CIVIL APPEAL NO(S). 229 OF 2022 (@ Special Leave Petition (Civil) No.30456 of 2019) WITH CIVIL APPEAL NO(S). 230 OF 2022 (@ Special Leave Petition (Civil) No.30607 of 2019) WITH CIVIL APPEAL NO(S). 231 OF 2022 (@ Special Leave Petition (Civil) No.30552 of 2019) WITH CIVIL APPEAL NO(S). 232 OF 2022 (@ Special Leave Petition (Civil) No.3157 of 2020) WITH CIVIL APPEAL NO(S). 233 OF 2022 (@ Special Leave Petition (Civil) No.322 of 2022) (@D.No.13480 of 2020) WITH CIVIL APPEAL NO(S). 234 OF 2022 (@ Special Leave Petition (Civil) No.323 of 2022) (@ D.No.14425 of 2020) AND WITH CIVIL APPEAL NO(S).235 OF 2022 (@ Special Leave Petition (Civil) No.324 of 2022) (@ D.No.23718 of 2020)

2022-01-07

Uday Umesh Lalit, J.

STATE OF UTTAR PRADESH & ORS.

ATUL KUMAR DWIVEDI & ORS.

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Nature of Litigation

Appeals against High Court judgment upholding normalization process in police recruitment.

Remedy Sought

Quashing of the final result dated 28.02.2019 and exclusion of candidates who qualified only through normalization.

Filing Reason

Challenge to the inclusion of candidates who secured more than 50% marks only after normalization in the selection process.

Previous Decisions

High Court of Judicature at Allahabad dismissed the writ petition challenging the normalization process.

Issues

Whether the normalization process adopted by the Board was valid. Whether candidates who secured 50% marks only after normalization could be considered qualified.

Submissions/Arguments

Appellants argued that candidates who did not secure 50% raw marks should not be included in the list of qualified candidates. Board submitted that normalization was necessary due to multiple sessions and different question papers, and candidates with 50% marks after normalization were eligible.

Ratio Decidendi

The Standardized Equi-percentile method for normalization of marks across different sessions of a written examination is permissible and does not violate the recruitment rules. Candidates who secure the minimum qualifying marks after normalization are eligible for further stages of selection.

Judgment Excerpts

Paragraph 4 of the notification dated 28.06.2017 thus stated that normalization of marks received, would be done as per 'Standardized Equi-percentile method' used in MAH-MBA/MMS CET 2015. In the reply dated 23.03.2019, filed by the Principal Secretary, Department of Home, Government of Uttar Pradesh to said Writ Petition, it was submitted:- 'It is further submitt...'

Procedural History

Writ Petition No.23733 of 2018 filed in Allahabad High Court in October 2018. Amendment allowed on 06.03.2019. Final result declared on 28.02.2019. High Court dismissed the petition. Appeals filed in Supreme Court.

Acts & Sections

  • Uttar Pradesh Sub Inspector and Inspector (Police) Service (1st Amendment) Rules, 2015:
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