Background:

The present writ petition concerns the alleged irregularities in the conduct of the NEET-UG
2024 examination, specifically allegations of a paper leak that have raised serious concerns
about the integrity of the examination process. The National Eligibility cum Entrance Test
(NEET-UG) is a critical examination for medical aspirants in India, determining admissions to
undergraduate medical programs. Any malpractice in the conduct of this examination not only
jeopardizes the careers of thousands of aspirants but also undermines public trust in the
examination system.

Numerous petitions have been filed before the Hon'ble Supreme Court of India challenging the
validity of the examination due to the alleged paper leak. Various student groups and aspirants
have raised concerns over unfair means being employed, resulting in an unjust advantage for
some candidates while others suffered due to the compromised nature of the test.

The issue has gained national attention, with demands for a thorough investigation and potential
re-examination being raised. The Hon'ble Supreme Court has acknowledged these concerns and
has scheduled hearings to address the grievances of the affected candidates. The matter involves
fundamental rights under Articles 14 (Right to Equality) and 21 (Right to Life and Education) of
the Constitution of India.

Synopsis:

1. Nature of the Case: This writ petition is filed under Article 32 of the Constitution of
India seeking judicial intervention in the irregularities surrounding the NEET-UG 2024
examination, including allegations of paper leaks and unfair means that have affected the
credibility of the examination process.
2. Petitioners: The petitioners are aggrieved students who appeared for the NEET-UG 2024
examination and have been adversely affected by the alleged leak. They seek relief in the
form of a thorough investigation and appropriate measures to ensure fairness in the
selection process.
3. Respondents: The respondents include the National Testing Agency (NTA), the Ministry
of Education, and other concerned authorities responsible for the conduct and
administration of NEET-UG 2024.
4. Legal Issues Involved:
o Violation of Article 14 (Right to Equality) due to the unfair advantage given to
certain candidates.
o Violation of Article 21 (Right to Education) as the examination process has been
compromised.
o The need for judicial oversight to ensure transparency and fairness in high-stakes
public examinations.
 5. Reliefs Sought:
o A court-monitored investigation into the allegations of paper leaks.
o Direction for a re-examination to ensure fairness and restore trust in the
examination process.
o Implementation of stricter security measures in future NEET examinations.

List of Dates:

1. May 5 2. 2024: NEET-UG 2024 examination conducted

nationwide.

3. May 6-10 4. 2024: Reports emerge on social media alleging

paper leaks in certain regions.

5. June 1 6. 2024: Multiple petitions filed before the Hon'ble

Supreme Court challenging the validity of the
examination.

7. June 10 8. 2024: The Supreme Court takes cognizance of

the issue and issues notices to the NTA and other
authorities.

9. July 18 10. 2024: The Supreme Court adjourns the hearing

and schedules the next date for further deliberation on
the matter.

The petitioners humbly seek urgent judicial intervention to address these concerns and uphold
the sanctity of the examination process.
 IN THE SUPREME COURT OF INDIA

(CIVIL ORIGINAL JURISDICTION)

Writ Petition (Civil) No. ............................... Of 2024

PUBLIC INTEREST LITIGATION

VANSHIKA YADAV
A/601, SAI DARSHAN COMPLEX,
MAMLATDARWADI ROAD NO.1,
MALAD (WEST),
MUMBAI – 40064.
EMAIL – VANSHIKAYADAV @[Link]
PH: 9833459554 … PETITIONER NO.1

VERSUS

1. UNION OF INDIA
MINISTRY OF EDUCATION
302-C, SHASTRI
BHAVAN,
New Delhi-110001 ....RESPONDENT NO. 1

2. NATIONAL TESTING AGENCY (NTA),

THROUGH ITS DIRECTOR GENERAL,
1ST FLOOR, NSIC- MDBP BUILDING,
OKHLA INDUSTRIAL ESTATE,
NEW DELHI-110020 …. RESPONDENT NO. 2

To,

THE HON’BLE CHIEF JUSTICE OF INDIA AND HIS COMPANION JUDGES

OF THE HON’BLE SUPREME COURT OF INDIA
The Humble Petition of
The Petitioners Above-named.
MOST RESPECFULLY SHOWETH:

1. The Petitioners have filed the instant Writ Petition (Mandamus) on the issue of validity
and integrity of the National Eligibility-cum-Entrance Test (Undergraduate) 2024
["NEET (UG) 2024"] conducted by the National Testing Agency on 5th May 2024. The
Petitioner seeks directions for the cancellation of the NEET (UG) 2024 examination and
for conducting a fresh examination due to multiple serious irregularities, paper leaks, and
systemic failures that have compromised the sanctity of the entire examination process.
2. The Petitioner is a 12 th Class Student who appeared for the NEET – UG examination for
admission in Medical Colleges. She Appeared for the examination on May 5, 2024 has
been mired in controversy due to allegations of paper leak, k, unfair practices, and arbitrary
awarding of grace marks leading to distorted results.
3. Following the declaration of results, various irregularities came to light which cast
serious doubt on the sanctity and integrity of the examination, including:

a. Paper Leakage: It has been established that there was a leak of the NEET (UG) 2024
paper at Hazaribagh in the State of Jharkhand and at Patna in the State of Bihar. The
Economic Offences Unit of Bihar Police has seized "admit cards, post-dated cheques, and
certificates" from members of an organized gang involved in this case.

b. Unprecedented Number of Perfect Scores: A total of 67 examinees achieved a

perfect score of 720/720, obtaining All India Rank 1. This is a drastic increase from
previous years where there were only 1-2 toppers annually from 2019-2023.

c. Statistically Improbable Scores: Several candidates received scores of 718 and 719,
which according to the examination's marking scheme should not be possible. While the
NTA has attributed this to "compensatory marks," the explanation lacks transparency and
raises further questions about the evaluation process.

d. Compensatory Marks Without Proper Verification: The NTA claims to have

awarded compensatory marks to 1,563 candidates based on alleged time loss during the
examination. The process of verification and the basis for awarding such marks remain
opaque and arbitrary.

e. Wrong Question Papers: In Sawai Madhopur (Rajasthan), Hindi-medium students

were mistakenly given English-medium question papers, leading to a walkout and
circulation of question papers outside the examination hall before the completion of the
examination.

f. Unusually High Cut-offs: The cut-off scores for qualification have increased
dramatically this year, raising questions about the integrity of the marking system and
potential artificial inflation of scores.
 g. Inconsistent Grace Marks: 44 of the 67 toppers were awarded "grace marks" for a
physics question because an older version of the NCERT textbook contained incorrect
information, raising questions about the fairness of the evaluation.

GROUNDS:

The Petitioner respectfully submits that the NEET (UG) 2024 examination should be
cancelled and a fresh examination should be conducted on the following grounds:

I. SYSTEMIC NATURE OF THE PAPER LEAK

1. The paper leak that occurred in Hazaribagh and Patna is not an isolated incident but
indicates a systemic failure in maintaining the confidentiality of the examination. The
involvement of organized gangs suggests a widespread network that may have benefited
numerous candidates across multiple centers.
2. The CBI's investigation has already identified approximately 155 students as potential
beneficiaries of the fraud, and this number is likely to increase as the investigation
progresses.
3. The systemic nature of the leak undermines the very purpose of a standardized national
examination, which is to ensure a level playing field for all candidates.

II. STRUCTURAL DEFICIENCIES IN THE CONDUCT OF THE

EXAMINATION

4. The multiple irregularities observed in the conduct of the NEET (UG) 2024 examination
- from wrong question papers being distributed to arbitrary award of compensatory marks
- reflect serious structural deficiencies in the NTA's examination management system.
5. The integrity of the examination has been further compromised by the premature
declaration of results, raising concerns about whether proper verification and scrutiny of
answer sheets was conducted.
6. The unexplained statistical anomalies in the results, including an unprecedented number
of perfect scores and statistically impossible marks of 718 and 719, suggest potential
manipulation of the evaluation process.

III. INABILITY TO SEGREGATE BENEFICIARIES FROM GENUINE

CANDIDATES

7. Given the nature and extent of the irregularities, it is impossible to accurately identify and
segregate all the beneficiaries of the paper leak and other malpractices from genuine
candidates.
8. The CBI's ongoing investigation indicates that more candidates may be identified as
beneficiaries of the fraud, but there is no certainty that all beneficiaries will be detected,
especially those who may have received advance information about the paper through
more discreet channels.
 IV. PRECEDENTS SET BY THIS HON'BLE COURT

9. This Hon'ble Court has previously ordered re-examinations in cases where the integrity
of the examination process was compromised. In Tanvi Sarwal vs Central Board of
Secondary Education and Others [(2015) 6 SCC 573] and Sachin Kumar and Others vs
Delhi Subordinate Service Selection Board (DSSSB) and Others [(2021) 4 SCC 631], this
Court held that when the sanctity of an examination is compromised, a re-examination is
the appropriate remedy.
10. The present case involves irregularities of a far more serious nature, affecting a
significantly larger number of candidates and with far-reaching implications for the
medical profession and public health in the country.

V. IMPACT ON MERIT AND FAIRNESS

11. The NEET (UG) examination is designed to select candidates based on merit for
admission to medical courses. The compromised integrity of the examination process
directly affects the meritorious selection of candidates and undermines the purpose of the
examination.
12. Allowing admissions based on compromised results would be a grave injustice to genuine
candidates who have prepared honestly for the examination and would adversely affect
the quality of future medical professionals.

VI. PUBLIC INTEREST AND FAITH IN THE EXAMINATION SYSTEM

13. The NEET (UG) examination is a crucial gateway for aspiring medical professionals.
Maintaining public faith in the fairness and integrity of this examination is essential for
the credibility of the entire medical education system.
14. The numerous irregularities in the 2024 examination have already caused widespread
public concern and distrust in the examination process. Failure to address these concerns
would further erode public confidence in the national testing system.

PRAYER:

In view of the facts and circumstances mentioned above, it is most respectfully prayed
that this Hon'ble Court may be pleased to:

a) Issue a writ, order, or direction in the nature of mandamus directing the Respondents to
cancel the NEET (UG) 2024 examination conducted on 5th May 2024;

b) Direct the Respondents to conduct a fresh NEET (UG) 2024 examination in a

transparent and fair manner, ensuring the integrity of the examination process;

c) Direct a thorough investigation into the systemic failures and irregularities in the
conduct of the NEET (UG) 2024 examination;
d) Direct the Respondents to implement robust mechanisms to prevent paper leaks and
other malpractices in future examinations;

e) Pass such other order or orders as this Hon'ble Court may deem fit and proper in the
facts and circumstances of the case.

AND FOR THIS ACT OF KINDNESS, THE PETITIONER AS IN DUTY BOUND

SHALL EVER PRAY.

Petitioner Through:

ARNIK JAIN
Counsel for the Petitioners

Drawn By: Arnik Jain

Drawn & Filled on: 20th July, 2024

New Delhi