Madhya Pradesh HC Dismisses PIL Challenging All India Bar Examination 2025 [Read Order]

Madhya Pradesh: The Madhya Pradesh High Court has dismissed a Public Interest Litigation challenging the results of the All India Bar Examination 2025, emphasizing that candidates who fail to meet the prescribed passing criteria cannot seek judicial intervention through a PIL.

A Division Bench comprising Acting Chief Justice Sanjeev Sachdeva and Justice Vinay Saraf delivered the judgment, addressing fundamental issues concerning examination standards and the maintainability of PILs in such matters.

The writ petition, filed by the petitioner Shrankhala against the Bar Council of India and others, sought a declaration that the AIBE 2025 results were arbitrary, unjust, and discriminatory. It further prayed for a direction to the Bar Council of India to refix the minimum passing marks in proportion to the number of valid questions and to re-evaluate and republish the result.

Addressing concerns over the conduct of the examination, the Court noted:
“According to learned counsel for the petitioner, 7 out of 100 questions were deleted by the Bar Council of India following objections raised by students. Consequently, the result was declared based on 93 questions. Counsel submits that the passing marks should be reduced proportionally.”

The Court highlighted the mathematical accuracy of the Bar Council’s approach, stating:
“As per the notification, the passing percentage was fixed at 45%. With 7 questions deleted, the number of remaining questions was 93. Accordingly, 45% of 93 is 41.85 marks.”

Referring to the petitioner’s own performance, the Court noted:
“Even if the petitioner’s contention is accepted, she is alleged to have answered only 39 questions correctly. As 45% of 93 amounts to approximately 42 marks, the petitioner has not met the minimum requirement even on her own terms.”

On the question of maintainability, the Court held:
“The petitioner participated in the examination and failed to qualify. A Public Interest Litigation at the behest of such a candidate is not maintainable.”

The petitioner was represented by Advocate Shri Vishnu Prasad, who contended that the reduction in total questions warranted a proportional reduction in passing marks. However, the Court found the argument untenable in view of the petitioner’s actual performance.

The judgment affirms that candidates who do not meet the qualifying threshold cannot invoke PIL jurisdiction to challenge examination outcomes when their scores fall short—even under their suggested revised criteria.

Case Title: Shrankhala vs. Bar Council of India & Ors.

[Read Order]