Anusha Gupta & Ors. v. National Testing Agency & Ors.

16. He submits that the NCFL report is rife with internal contradictions and technical flaws. He submits that despite an admission in the report itself that petitioner no.1’s scorecard was downloaded on 11.02.2025 at 18:08:45 and that a file with matching timestamp exists on her laptop, the report has raised doubts with regard to the file’s source and authenticity since there exists a ‘gap’ in the browsing logs.

17. Explaining the said purported ‘gap’, he submits that the same appears simply because after having accessed the scorecard from the website of NTA, petitioner no.1 focused on her studies and next used the browser only the following morning. He submits that absence of any activity does not generate a log entry in the internet browser, thus, there is no proof of any voluntary ‘omission’, as stated in the report.

18. Similarly, he submits that the report is equally silent with respect to petitioner no.2’s case, where although, the metadata with respect to his scorecard is found to be present, but emphasis has been laid on mere log gaps without there being any evidence of intentional deletion, tampering or use of cleaning tools.

19. Mr. Jain contends that the report has drawn conclusions of tampering and manipulation, with regard to the response sheet of petitioner no.1, through use of ‘DevTools’ based on metadata and cache discrepancies. However, no analysis has been done to show whether such discrepancies have occurred due to actions of the petitioner or whether the purported actions have led to any modifications or tampering of the scorecards and response sheet.

20. As regards the alleged emails sent by NTA along with the official scorecards of petitioners to their respective email IDs, Mr. Jain contends that the report is fundamentally incomplete, as NCFL plainly admits it is unable to verify whether the specific email communication was received or accessed by petitioner no.1.

21. Per contra, Mr. Sanjay Khanna, learned standing counsel for the respondent no.1/NTA submits that present petition deserves to be dismissed at the outset on the ground that the petitioners have not approached this Court with clean hands. He submits that the petitioners’ entire claim is based on manipulated scores. It is stated that as per official NTA records, percentile of petitioner no.1 in Session I was 25.5874923, not 98.6874923, and petitioner no.2 obtained 80.4107035, not 94.8107035.

22. He invites attention of the Court to the report of the NCFL to submit that a clear finding has been given as to the tampering done by petitioners. With regard to petitioner no.1’s scorecard, he submits that NCFL’s report has given an observation that there is a significant gap in the data where Chrome browsing history from 17:19:48 on 11.02.2025 to 09:44:43 on 12.02.2025 is missing. Such a gap suggests that there has been intentional deletion, usage of cleaning tools prior to submission of the device for investigation or use of a separate device for accessing the NTA website, which device has not been produced in Court.

23. He submits that in the writ petition, it has been claimed that the scorecard was downloaded at 17:28 on 11.02.2025, however, analysis of the metadata shows that the download was done at 18:08:45. Furthermore, he refers to activity logs enclosed with the letter dated 07.05.2025 of respondent no.2/NIC to submit that the same show web access at 17:48 and 17:58 on 11.02.2025 by petitioner no.1. He contends that the inconsistencies in the petitioners’ version and missing browser entries are clear indication of manipulation, selective deletion of local browser traces or use of a separate device.

24. Similarly, as regard petitioner no.2, he submits that the log entry corresponding to the time interval between 06:01:28 to 06:10:16 on 12.02.2025 is absent which again indicates an intentional act of deleting the evidence before handing over the device for forensic analysis.

25. Mr. Khanna further argues that irrefutable proof of the manipulation by the petitioners lies within their own relied upon scorecards. He submits that every scorecard issued by the NTA contains a QR Code, which when scanned, redirects to the official scorecard of the candidate. In the present case as well, scanning of QR Code contained in the scorecards relied upon by the petitioners, shows the petitioners’ scores as per the official record of the NTA, and not the inflated scores that they have claimed.

26. He places reliance on the judgment of the Hon’ble Bombay High Court in Shantanu Bhopale v. Union of India, 2025:BHC-AS:20174-DB to support his contention that QR Code is included in all the scorecards published by NTA with the intent to provide verification that the contents appearing in the document co-relate with the official records of NTA.

27. Mr. Khanna further states that as per the established scheme of the examination, results of candidates are sent to their registered email IDs and the parents’, with a blind copy to NTA. He submits that these email addresses are provided by the candidates themselves at the time of registration and are used for all important communications. Placing reliance on the letter dated 07.05.2025 of NIC, he submits that such emails were sent to the registered email IDs of petitioners on 12.02.2025 and 19.04.2025 for Sessions I and II respectively.

28. Lastly, he submits that the present case is a clear case of false averments. At best, the petitioners have raised disputed questions of fact which cannot be adjudicated in writ proceedings. Reliance has been placed on the decision of this Court in Aishani Ojha v. NTA & Ors., 2022 SCC OnLine Del 2604, Gaurav Jaiswal v. Union of India & Ors., 2021 SCC OnLine Del 3456, Tanishq Mishra v. NTA & Ors., 2022 SCC OnLine Del 2482 and Vibhuti Negi v. National Testing Agency and Ors., 2024 SCC OnLine Del 4235.

29. I have carefully examined the material on record, as well as, the rival contentions of the parties.

30. As already noted above, in view of the joint request of parties and having regard to the nature of dispute, as well as, the vehement assertion of the petitioners as to the veracity of the scorecards relied upon by them, this Court deemed it fit to obtain opinion of experts from a technical standpoint. Thus, vide order dated 14.05.2025, the matter was referred to CFSL for technical analysis with due consent of the parties. In the said order, submission of Mr. Jain was recorded to the effect that petitioner no.1’s downloaded scorecard and her response sheet for Session I were available in unedited form on her laptop. Similarly, petitioner no.2’s downloaded Session I scorecard and the composite scorecard were said to be available on two separate laptops.

31. The petitioners were, therefore, directed to produce the said three laptops in Court, which were subsequently sent to CFSL in a sealed cover. In addition, pursuant to this Court’s earlier order dated 06.05.2025, pen drive placed on record by the petitioners in a sealed cover, was also sent for analysis.

32. However, in view of the letter dated 19.05.2025 from Director, CFSL expressing inability to conduct the enquiry, the matter was forwarded to NCFL vide order dated 20.05.2025 for forensic analysis. Finally, the forensic report of NCFL dated 13.06.2025 was submitted, which was taken on record.

33. Before proceeding further, it would be appropriate to refer to the relevant excerpts of the aforesaid NCFL report dated 13.06.2025 with regard to the allegations and claims of the petitioners, as elaborated hereinabove.

34. On the basis of examination of the material provided to NCFL, following observations have been made in the report with regard to the scorecard of petitioner no.1: “As per the screenshots provided by Petitioner 1, the scorecard was downloaded on 11.02.2025, at 18:08:45, and the corresponding file with the same timestamp was found on Petitioner 1’s device. During the forensic review of the Chrome browsing history submitted by Petitioner 1, a significant data gap was identified. Specifically, no browser activity was recorded between 17:19:48 on 11.02.2025, to 09:44:43 on 12.02.2025. Due to the absence of browser logs during this interval, it is not possible to conclusively determine whether the scorecard was downloaded directly from the official website of the National testing Agency (NTA). The critical log entries that would typically confirm such a transaction are not present in the browsing history submitted by Petitioner 1, thereby precluding verification of the origin of the downloaded scorecard. xxx xxx xxx The scorecard was found on Petitioner 1’s device and the same is reported (via screenshot) by petitioner 1, which was downloaded on 11.02.2025, at 18:08:45. The authenticity of this scorecard cannot be independently verified, as the Google Chrome browsing history provided by Petitioner 1 contains a significant omission of logs between 17:19:48 on 11.02.2025 to 09:44:43 on 12.02.2025. As a result, there is no verifiable log entry confirming that the scorecard was downloaded from the official NTA website during this timeframe.” (emphasis supplied)

35. As regards the response sheet of petitioner no.1, the findings and observations recorded in the NCFL report read thus: “b. During the forensic examination of Petitioner 1’s laptop (Exhibit-01), it was determined that the response sheet had been accessed, modified, and subsequently downloaded in an altered state. System timeline analysis revealed that Petitioner 1 logged into the NIC candidate portal on 04.02.2025, at 17:38:01, and subsequently viewed the response sheet in HTML format at 17:41:24. This access event was corroborated by artifacts found in the Google Chrome cache. Supporting evidence is documented in Annexure A – Petitioner 1 (Pages 1 & 2). Further analysis of the timeline indicates that Petitioner 1 launched Chrome Developers Tools (DevTools) on 04.02.2025, at 17:53:12, during which the HTML page containing the response sheet was actively loaded and inspected. This event is an indication of manual interaction with the document structure. The relevant evidence is presented in Annexure A – Petitioner 1 (Page 3). For context, Chrome DevTools is a suite of web development utilities integrated into the Chrome browser, designed for inspecting, debugging, and editing HTML, CSS, and JavaScript content in real-time. Subsequently, the modified version of the response sheet for Session 1 was downloaded on 04.02.2025 at 23:49:09. This file is also presented in Annexure A – Petitioner 1 (Page 4). A comparative analysis was conducted between the original response sheet (retrieved from the Chrome cache prior to modification) and the downloaded, modified version. The comparative table, included in Annexure A – Petitioner 1 (Pages 5-58), reveals the following discrepancies: Sr. No. Description Response Sheet found in Google Chrome Cache Response Sheet Downloaded

1. Attempted Questions 49 62

2. Un-attempted Questions 26 13 Additionally, audit logs provided by National Testing Agency (NTA) confirms that Petitioner 1 had officially attempted 49 questions, while 26 questions were left unattempted in Session 1. These audit records are included in Annexure A – Petitioner 1 (Pages 59 & 60).”

36. Furthermore, NCFL has given the following opinion after analysis of the devices and documents submitted by petitioner no.2 in respect to his scorecard, which reads thus: “The investigation revealed that Petitioner 2 successfully logged into the official portal of the National Testing Agency (NTA) and accessed the answer key on 05.02.2025 at 02:45:36. This event is documented and annexed in Annexure B – Petitioner 2 (Page 1). However, the Chrome browsing history provided by Petitioner 2 does not contain any entries corresponding to the date and time of viewing or downloading the response sheet and scorecard. Due to the absence of relevant log entries, it is not possible to conclusively determine whether these files were downloaded from the official NTA website. c. Based on the screenshot of the scorecard submitted by Petitioner 2, the scorecard was downloaded on 12.02.2025 at 06:07:41, and a corresponding file with the same timestamp was identified on Petitioner 2’s laptop. During the timeline analysis of Petitioner 2’s laptop, designated as Exhibit-03, the scorecard file was identified within the system’s Jump List records. However, no corresponding entry was found in the browser history, indicating that the file may have been accessed or opened, but its original source or method of acquisition could not be conclusively verified. Upon analysis of the Chrome browsing history furnished by Petitioner 2, it was observed that log entries corresponding to the time interval between 06:01:28 to 06:10:16 on 12.02.2025 are absent. Notably, the scorecard in question was downloaded during this undocumented period. Consequently, it is not possible to ascertain whether the referenced files were altered or tampered with prior to their download during Session 1. The aforementioned activities indicate that the browsing history of Petitioner 2 during the time interval from 06:01:28 to 06:10:16 on 12.02.2025, which was partially recovered in the timeline analysis, was found to be missing in the browsing history provided by Petitioner 2.”

37. Finally, observations of NCFL regarding the allegations in Session II of JEE (Main) – 2025 are as under: “Furthermore, the petitioner has stated that the response sheet for Session 2 was downloaded, while the browsing history between the duration 21:33:26 on 03.04.2025 to 22:01:33 on 01:05:2025 is missing from the records provided by Petitioner 2. Additionally, no file corresponding to the Session 2 response sheet was located on laptop of Petitioner 2. Due to this it cannot be opined whether the petitioner has modified/tampered the response sheet and scorecard for session 2.”

38. Upon careful perusal of the report furnished by NCFL, especially having regard to the findings recorded in respect of the scorecards of petitioner nos.[1] & 2 for Session I, it appears that the relevant and critical log entries that ought to have been present in the browsing history, are absent.

39. It must be noted that as per the report, petitioner no.1 had downloaded her scorecard at 18:08:45 on 11.02.2025 while petitioner no.2 had downloaded his scorecard at 06:07:41 on 12.02.2025. The said observation is consistent with the scorecards placed on record and relied upon by the petitioner nos.[1] & 2 themselves.

40. The scorecard produced by the petitioner no.1 shows that on the top left corner of the scorecard, date and time mentioned as “2/11/25, 6:08 PM”, denotes the time of download of the document, while the bottom right corner records the time of access as “11/02/2025 17:58:16”.

41. Likewise, time of download on the top left corner of petitioner no.2’s scorecard has been noted as “2/12/25, 6:07 AM”, and time of access has been shown as “11/02/2025 20:17:39” at the bottom right corner of the scorecard relied upon by him.

42. After going through the relevant data points, the report comes to a conclusion that although, files containing the scorecards can be located on the laptops given by the petitioners, however, browsing history for the relevant time cannot be found. For petitioner no.1, browsing data from 17:19:48 on 11.02.2025, to 09:44:43 on 12.02.2025, is found to be missing. Intriguingly, the scorecards, relied upon by petitioner no.1 was accessed and downloaded within this gap itself.

43. Similarly, from petitioner no.2’s device, browsing data from 06:01:28 to 06:10:16 on 12.02.2025 was missing. This is the period when scorecard has been downloaded by petitioner no.2, as per the analysis of technical experts, as well as, according to the document relied upon by petitioner no.2 himself.

44. In this regard, it must be noted that it is the specific case of the petitioners, as stated above and noted in order dated 14.05.2025, that the devices submitted by them were the same in which the petitioners had downloaded the respective scorecards from the official website of respondent no.1/NTA, and further that the said laptops were submitted without there being any tampering or editing.

45. However, no convincing justification has been put forth to explain as to how there exists no browsing history for the relevant time period. Mr. Jain has sought to dispute the report of NCFL by arguing that no analysis has been done as to how the browsing history could have gone missing and whether the same was done intentionally by the petitioners. The said argument is not tenable. The browsing history for the specific time period which would have clarified the entire factual position is conspicuously missing. Such absence of the specific logs cannot be assumed to be a random occurrence. Considering that petitioners have failed to either preserve the relevant records or explain the absence of the aforesaid crucial logs, this Court is inclined to draw adverse inference against them.

46. Even otherwise, without the browsing history or any other supportive document, this Court is not persuaded to believe the version of petitioners that the scorecards were downloaded from the official website of the record produced by the NTA.

47. On the other hand, NTA has been able to show that as per the official records, petitioners have obtained the respective percentiles as recorded in the final composite scorecards. This Court also finds substance in the following contentions articulated by NTA in its counter affidavit, which remain uncontroverted:

(i) The QR Codes, contained in the scorecards on which petitioners have placed reliance, upon scanning show the scores as per the official record of the NTA and not the inflated ones claimed by the petitioners.

(ii) The claim of the petitioners is otherwise, mathematically impossible and is also contradictory to the established Normalization Process, a standard practice for comparing candidate scores across multi-session papers. The petitioner no.1 claims that her raw score is 183 as the same corresponds to a percentile of 98.6874923, however, according to NTA’s official record, a total of 47 candidates in that session scored a raw score of 183. Upon applying the standard declared formula, all 47 of these candidates were correctly awarded a percentile of 98.9266163. The petitioner no.1’s claimed percentile does not match the actual, calculated percentile for her claimed raw score. (iii)In the column for the “Total in words,” the petitioner’s document uses an uppercase ‘P’ in the word ‘Point’, viz. “Ninety-Eight Point Six Eight Seven Four Nine Two Three Only.” This is a clear deviation from the standard format, as all genuine scorecards issued by the NTA are pre-programmed to use a lowercase ‘p’, as seen in the petitioner's original scorecard, which reads “Twenty-Five point Five Eight Seven Four Nine Two Three Only”. (iv)In the document submitted by the petitioner no.1, the Physics score is reflected only up to 6 decimal places (98.941892). However, the official NTA system is programmed to display all scores consistently up to 7 decimal places. The petitioner no.1’s actual Physics score, for instance, is 41.1941892. This standard is so rigid that even a candidate who obtains a perfect 100 percentile has their score displayed as 100.0000000.

48. Respondent no.2/NIC, the technical partner of NTA, has also issued a letter dated 07.05.2025 [annexed along with the counter affidavit of respondent no.1] which confirms that the scorecards of all candidates, including the petitioners herein, have been uploaded only once with there being no change since the said first upload.

49. Coming to the allegation of petitioner no.2 with regard to his attempt in Session II, it is stated in the petition that the petitioner no.2 appeared for Session II examination on 04.04.2025. The specific grievance is to the recorded response sheet for Session II uploaded by the respondent no.2/NTA, wherein upon perusing the same, petitioner no.2 observed certain irregularities. He alleges that the questions as attempted by him during the examination, were subsequently not marked/recorded in the same manner when the response sheet was uploaded.

50. It must be observed that the composite scorecard declared after Session II, was uploaded on 18.04.2025, while the exam itself was conducted on 04.04.2025. It would not be out of place to assume that response sheet for Session II ought to have been uploaded between the said period. However, report of NCFL, in clear terms, has stated that the browsing history in the devices provided by petitioner no.2 are missing for the period 03.04.2025 to 01.05.2025 which encompasses the time when petitioner no.2 could have viewed the response sheet uploaded by NTA. Therefore, in the given circumstances, it cannot even be said with certainty as to when the petitioner no.2 had accessed his response sheet and from which website.

51. Incidentally, the alleged irregularities qua Session II cannot be examined as petitioner no.2 has not substantiated his allegations with either the purported response sheet, or any other document which would inspire confidence with regard to the allegations made.

52. Finally, the forensic analysis report by the NCFL has rendered a clear and detailed finding with regard to the response sheet relied upon by petitioner no.1, for Session I. Analysis of the data from the laptop of petitioner no.1, as submitted by her, reveals that the response sheet uploaded on the website of NTA, was accessed by petitioner no.1 in HTML format at 17:41:24 on 04.02.2025. Thereafter, Chrome Developers Tools [hereafter ‘DevTools’] was launched at 17:53:12 on the said device. During this time, it has been noted that the page containing the response sheet was actively loaded and inspected. In the report, it has been stated that such DevTools, which are integrated into the Chrome browser, can be used for editing HTML content.

53. Clearly, the means of tampering, changes made and discrepancies as noted by NCFL in its report and explained in detail in the annexures thereto, leave no manner of doubt that the response sheet relied upon by the petitioner no.1 is not genuine. In light of the detailed explanation provided in the report, Mr. Jain’s contention that it has not been shown as to whether the said DevTools had been launched deliberately and that the same led to any modifications, is not tenable. No automatic computer event can lead to specific outcomes such as the modifications that have come to light in the report with regard to the response sheet relied upon by petitioner no.1.

54. As noted above, this Court had deemed it fit to obtain the opinion of technical experts, precisely to bring on record facts that could only be ascertained through forensic analysis of computer data. This exercise was undertaken on the joint request of parties and the scope of enquiry was limited to the data in the respective devices of petitioners, particularly in light of the confidence exhibited by the petitioners as to the genuineness of the documents relied upon by them.

55. The report of the expert body has now come on record with clear findings which do not support the petitioners’ case. The petitioners now cannot be allowed to question the reliability of the report on grounds of flawed technical reasoning, and the findings being premised on incomplete data. The contentions of the petitioners in that behalf do not convince this Court.

56. Furthermore, NTA is an autonomous body of Department of Higher Education under the Ministry of Education which is responsible for conducting numerous national level exams for admission and fellowship in higher educational institutions. The official records maintained by NTA cannot be doubted without credible or convincing evidence. There is a presumption in favour of such official records under Section 1141 of the Indian Evidence Act, 1872. Reference in this regard may be had to the Equivalent to section 119 of the Bharatiya Sakshya Adhiniyam, 2023. decision of a Coordinate Bench of this Court in Selishia Mohandas v. Union of India, Through its Director and Others, 2023 SCC OnLine Del 4973 wherein it was observed as under: “18. The specific submissions have been made by respondent no.2-NTA in its counter affidavit and the original OMR sheet has also been presented. The record produced by the respondents is the official record. There is no reason to doubt the genuineness of the same.

19. There is a presumption in favour of the official record in terms of Section 114 of the Indian Evidence Act, 1872. In absence of any concrete document to rebut the presumption, the correctness of the official record cannot be doubted.

20. There is no reason to believe that respondent no.2-NTA would fabricate or replace the marks obtained by any of the candidates. Respondentno.2-NTA has no personal stake.”

57. It must also be noted that this Court is exercising writ jurisdiction under Article 226 of the Constitution. Although, Constitutional Courts have discretionary power to enquire into questions of fact, but such discretion must be exercised in exceptional cases and not ordinarily adjudicate upon disputed facts. Considering the report of technical experts, this Court is of the view that petitioners have failed to establish their bona fides, and thus, no exception can be carved out at their behest.

58. This Court, in similar circumstances, has refused to entertain writ petitions of unscrupulous litigants. Reference in this regard may be had to the decision of this Court in Vibhuti Negi (supra), wherein it was held as under:

response sheet should be accepted, and the second score card and second response sheet declared illegal.

36. Any further enquiry into the controversy would require the court to enter into a dense factual thicket, which cannot be undertaken under Article 226 of the Constitution of India. Suffice it, therefore, to state that, in exercise of Article 226 jurisdiction, this Court is, in the facts before it, unable to accept the petitioner's assertion that two response sheets and two score cards had been issued by the NTA.”

59. In Tanishq Mishra (supra), this Court held thus: “20. The upshot of the above discussion is that the Petitioner does not have the response sheets to authenticate his scores, which could perhaps have supported his version. On the other hand, digital records produced by NTA, system-generated emails, QR mismatch, response sheets with audit log, login details for accessing website, as maintained and authenticated by NIC, all point the case to the contrary. While Petitioner may continue to assert that his documents are authentic, however, on the basis of facts and documents shown, this Court cannot come to this conclusion. The question of forgery and tampering of records can only be determined after the parties have been afforded an opportunity to lead evidence, and this exercise cannot be undertaken in the present proceedings. The Petitioner has failed to prove his bona fides. The Court remains unconvinced of the genuineness of the Petitioner's documents. Thus, there is no basis to grant relief to the Petitioner.”

60. Likewise, in Aishani Ojha (supra) it was held as under:

a computer system wherein every movement of a candidates' cursor on the screen and their responses are recorded and stored in an electronic database in the form of audit logs, that have been duly produced before the Court. The record/documents relied on by the parties, particularly the response sheet and the audit log for session 2 of JEE (Main) of Petitioner have been scrutinized. As per the audit log, Petitioner cleared responses to several questions after having already attempted/selected a response thereto. While Petitioner has persistently contended that the same are recorded erroneously, the Court finds no reason to believe such speculations. The audit log maintained by the NTA records not only the selected response, but also the number of times a candidate has visited the question, response so selected/entered on a real-time basis. Petitioner has also failed to demonstrate that she had indeed attempted 75 questions. Her version is contradicted by the verified electronic record of NTA, which is maintained by National Informatics Centre. No technical error is manifest and thus, the Court remains unconvinced of Petitioner's claim that a technical snag in the system has resulted in low score in JEE (Main).”

61. In view of the above, the present petition is dismissed. Pending applications are disposed of as well.

62. The Registry is directed to hand over the devices of petitioners, deposited in pursuance to order dated 14.05.2025, to the respective petitioners or the counsel representing them.

63. Further, having regard to the abundant efforts dispensed by several government agencies to scrutinize allegations of the petitioners and authenticity of their claims, this Court is inclined to impose a cost of Rs.30,000/- each upon petitioner nos.[1] & 2. The imposition of such cost will be deterrent for unscrupulous litigants from approaching Courts with unclean hands.

64. Therefore, petitioner nos.[1] and 2 are directed to deposit costs of Rs.30,000/- each towards the “Chief Justice Disaster Relief Fund 2025” established by Hon’ble the Chief Justice, High Court of Himachal Pradesh, within a period of two weeks.

VIKAS MAHAJAN, J SEPTEMBER 22, 2025