Limits of Judicial Review in Examination Matters: Supreme Court Holds High Courts Cannot Act as Super-Examiners

Introduction

The delicate balance between judicial review and administrative expertise has long been a subject of intense jurisprudential debate in India. This balance becomes particularly nuanced when courts are called upon to examine matters requiring specialized knowledge or technical competence. In a significant ruling delivered in February 2026, the Supreme Court of India emphatically reaffirmed the principle that courts cannot assume the role of super-examiners or subject experts, even in matters relating to judicial service examinations where judges themselves might possess considerable expertise. The bench comprising Chief Justice Surya Kant and Justices Joymalya Bagchi and NV Anjaria held that such exercises should ordinarily be left to domain experts, marking an important statement on the limits of judicial review in technical and specialized matters [1].

The case arose from an appeal filed by the Jharkhand Public Service Commission challenging an order of the Jharkhand High Court that had directly corrected answer keys for the Civil Judge (Junior Division) examination. The High Court, exercising its judicial review powers, had found certain answers in the examination to be incorrect and had directed the JPSC to award marks accordingly. The Supreme Court, while partly setting aside this order, directed that such matters should be referred to expert committees rather than being decided directly by the court in its judicial capacity. This decision has profound implications for the limits of judicial review in examination matters and the relationship between courts and administrative bodies possessing specialized expertise.

Factual Background and Disputed Questions

The controversy centered around three specific questions that appeared in the Jharkhand Civil Judge (Junior Division) examination conducted by the JPSC. The examination, which forms the preliminary stage of recruitment to the state judicial service, attracts thousands of aspirants and is governed by stringent protocols regarding question-setting and answer key preparation. The disputed questions numbered 8, 74, and 96 in Series A of the question paper became the subject of writ petitions filed by aggrieved candidates who challenged the correctness of the answers marked by the JPSC.

Question 8 required candidates to identify the grammatically correct English sentence. The JPSC had initially marked one option as correct but later revised the answer key to mark a different option. The candidates contended that the sentence “More than one boy was absent from the class” was grammatically correct, whereas the JPSC’s revised answer key indicated “More than one boy were absent from the class” as the correct answer. This question involved the application of English grammar rules regarding subject-verb agreement when the phrase “more than one” is used, a matter that has long been debated among grammarians.

Question 74 tested knowledge of a specific Supreme Court judgment in the case of Ashwini Kumar Upadhyay v. Union of India, asking which sections of the Indian Penal Code were mentioned by the Supreme Court in that order. The JPSC had marked an option listing Sections 153A, 153B, 295A, and 506 as correct. However, the candidates pointed out that Section 506 was not mentioned in the actual Supreme Court judgment, while Section 505 was. This discrepancy raised questions about whether the examination authority could take liberties with the interpretation of judicial pronouncements or whether absolute fidelity to the text was required.

Question 96 related to the law of agency under the Indian Contract Act, 1872. The JPSC had initially indicated one option as correct but subsequently changed it during the revision of the answer key. The candidates argued that the revised answer was legally incorrect and that multiple options could be considered correct based on the proper interpretation of the relevant provisions of the Contract Act. This question involved the application of substantive legal principles regarding agency, competence, and formalities required for creating agency relationships.

The High Court’s Approach and Reasoning

The Jharkhand High Court, exercising its writ jurisdiction, examined each of the three disputed questions in detail. The Court undertook what can be characterized as a substantive review of the correctness of the answers, going beyond merely examining whether the JPSC had followed proper procedures in setting or revising the answer key. In its analysis of Question 8 regarding English grammar, the High Court categorically held that the option stating “More than one boy was absent from the class” was the correct answer and that the JPSC’s revised answer was incorrect. The Court applied grammatical rules to arrive at this conclusion, effectively substituting its own judgment for that of the examination authority [2].

With respect to Question 74 concerning the Supreme Court judgment, the High Court examined the original judgment in Ashwini Kumar Upadhyay v. Union of India and found that Section 506 of the IPC was indeed not mentioned in that order, while Section 505 was. The Court rejected the JPSC’s argument that the word “etc.” used in the Supreme Court’s order could be read to include Section 506, observing that such an interpretation would be overly broad and could theoretically include every section of the Indian Penal Code. This reasoning demonstrated the High Court’s willingness to engage in textual analysis of Supreme Court judgments to verify the correctness of examination questions.

In analyzing Question 96 on the law of agency, the High Court examined the relevant provisions of the Indian Contract Act, 1872, particularly Sections 184 and 186. The Court found that the JPSC’s revised answer was incorrect and that multiple options could be considered legally accurate. The Court held that both candidates who marked certain options should be given credit, as those options represented correct legal propositions even though the question had been designed to identify an incorrect statement. This approach demonstrated the Court’s readiness to apply its legal expertise to correct what it perceived as errors in legal reasoning by the examination authority [2].

Based on its analysis, the Jharkhand High Court allowed the writ petitions and directed the JPSC to give one mark to persons who answered Option A in Question 8 and to delete Questions 74 and 96 from consideration entirely. This relief had the effect of altering the final merit list, as some candidates would gain marks while the scoring for all candidates would be adjusted by excluding two questions. The High Court’s order thus directly interfered with the examination process and imposed its own view of correctness on technical and subject matter questions.

The Supreme Court’s Intervention and Key Observations

The Jharkhand Public Service Commission approached the Supreme Court challenging the High Court’s order, primarily contending that the High Court had exceeded its jurisdiction by assuming the role of a super-examiner. The JPSC argued that while courts possess the power of judicial review over administrative actions, this power does not extend to substituting the court’s own expertise for that of domain experts in technical or specialized matters. The Supreme Court bench led by Chief Justice Surya Kant took note of this submission and recognized the fundamental issue at stake regarding the proper scope of judicial review.

At the outset of the hearing, the Supreme Court bench remarked that if the High Court found the revised answers to be in need of reconsideration, the appropriate course would have been to remand the matter to the Commission with directions to re-examine the answer key through a proper expert committee, rather than the Court itself determining the correctness of the answers. This observation signaled the Court’s concern about the approach adopted by the High Court and set the stage for a more detailed analysis of the limits of judicial review in examination matters.

The Supreme Court acknowledged that judicial service examinations present a unique situation where the judges of the High Court, by virtue of their vast experience on the Bar and Bench, could be expected to have a better understanding and appreciation of legal questions put to candidates. However, the Court held that this fact alone could not justify the High Court assuming the role of a super-examiner or subject expert. The Court emphasized that the question was whether the power of judicial review in matters of re-evaluation, re-appreciation, or reconsideration of answer keys would apply uniformly, irrespective of the nature of the examination [1].

In a crucial passage that forms the cornerstone of this judgment, the Supreme Court held that the High Court cannot assume the role of super-examiner or subject expert, and such exercises should ordinarily be left to domain experts. This principle was articulated despite acknowledging that the subject examination pertained to recruitment to judicial services. The Court’s reasoning rested on the understanding that specialized knowledge, whether in English grammar, interpretation of judgments, or application of legal principles, requires the input of domain experts rather than being decided through judicial pronouncement [1].

The Supreme Court further observed that the JPSC had claimed that the answer key was duly vetted by the High Court on the administrative side. If this was indeed the case, the Court held that it would have been necessary for the High Court, while exercising its judicial authority, to refer the matter to the respective committee of the High Court as well as to the JPSC for formation of an additional committee comprising subject experts. For Question 8 involving English grammar, the Court specifically noted that such a committee should include eminent law professors as domain field experts along with a Professor of English to provide assistance and guidance [1].

The Supreme Court’s order partly set aside the High Court’s decision to the extent that it determined the correctness of the answer key. However, recognizing that legitimate concerns had been raised about the disputed questions, the Court did not simply restore the JPSC’s original answer key. Instead, the Supreme Court directed the Jharkhand High Court to constitute an expert committee on the administrative side to re-examine the correctness of the three questions. This committee’s opinion was to be sent back to the JPSC for necessary action within two weeks. This remedial approach balanced the need for proper examination of disputed answers while maintaining the principle that such examination should be conducted by domain experts rather than by courts in their judicial capacity.

Scope of Judicial Review in Examination Matters

The Supreme Court’s decision in this case must be understood within the broader framework of judicial review of administrative action in India. The power of judicial review is a basic feature of the Indian Constitution and enables courts to examine the legality, procedural fairness, and reasonableness of administrative decisions. However, this power has recognized limits, particularly when courts are called upon to review decisions involving technical expertise, policy choices, or matters requiring specialized knowledge. The doctrine of restraint in judicial review acknowledges that courts should not substitute their own views for those of administrative authorities in matters where the latter possess greater expertise or where the Constitution has reposed decision-making authority in such bodies.

In the context of examination disputes, Indian courts have evolved a nuanced jurisprudence that distinguishes between reviewing the process of examination and answer-key preparation on one hand, and substituting judicial opinion for expert evaluation on the other. Courts have consistently held that they can intervene when there are allegations of mala fides, arbitrariness, procedural irregularities, or violations of fundamental rights. However, courts have generally been reluctant to sit in appeal over the academic or technical judgment of examination authorities, recognizing that such authorities are better equipped to evaluate the correctness of answers in specialized subjects [3]. This approach demonstrates the careful limits of judicial review in examination, ensuring that judicial intervention is exercised only when legally warranted.

The Supreme Court has in several decisions articulated the principle that courts should not ordinarily interfere with academic matters or the evaluation of answer keys unless there is a patent error on the face of the record or the decision is shown to be completely arbitrary or unreasonable. In previous cases, the Court has held that mere difference of opinion regarding the correctness of an answer is not sufficient ground for judicial intervention. The court must be shown that the answer given is demonstrably and patently wrong, leaving no room for any other interpretation or academic debate.

The Delhi High Court has similarly held that judges are not and cannot be experts in all fields, and the opinion of experts cannot be supplanted by a court overstepping its jurisdiction. In a case concerning the Foreign Medical Graduate Examination, the Delhi High Court set aside a single judge’s order that had awarded marks to candidates after finding an examination question to be erroneous. The Division Bench observed that it would not be prudent for a court to conduct itself like an expert in a subject alien to it when an entire body of experts had arrived at a contradictory stand [4]. This principle has been applied across various examination disputes involving medical, engineering, and other technical subjects.

Courts have also recognized that in examination matters, candidates must demonstrate that the answer keys are patently wrong on the face of it, not merely that alternative interpretations are possible. This standard ensures that judicial intervention remains exceptional and does not open the floodgates to challenges in every examination where candidates disagree with the marking or evaluation. The threshold for intervention is therefore kept deliberately high to maintain the integrity of the examination process and to respect the expertise of those entrusted with conducting examinations.

The Role of Expert Opinion in Legal Proceedings

The Supreme Court’s emphasis on referring matters to domain experts rather than courts directly deciding them resonates with the broader legal framework governing expert evidence in India. The Indian Evidence Act, 1872, through its provisions on expert opinion, recognizes that courts require assistance from persons with specialized knowledge in matters involving science, art, foreign law, handwriting, finger impressions, and other technical subjects. These provisions acknowledge that judges, despite their legal training and experience, cannot be expected to possess expertise in every field that might become relevant in legal proceedings [5].

The law relating to expert evidence establishes that when the subject matter of inquiry relates to science or art requiring previous study and training, and inexperienced persons are unlikely to form correct judgment, the opinions of skilled persons in their respective areas become relevant and admissible. However, expert evidence is treated as opinion evidence rather than substantive evidence, meaning it must be corroborated by other evidence and cannot alone form the basis of a decision. Courts retain the power to accept or reject expert opinion after careful consideration, but they must provide reasons for departing from expert views [5].

The Supreme Court has held in numerous cases that expert evidence should be subjected to cross-examination because experts, like any other witnesses, are fallible. The real value of expert evidence lies in the rightful inferences that experts draw from their observations based on specialized knowledge, not from mere surmises. Courts must carefully evaluate the qualifications, experience, methodology, and reasoning of experts before accepting their opinions. When expert opinions conflict, courts must analyze the basis of each opinion and determine which is more consistent with other evidence and established principles in the field [6].

In the context of examination disputes, the principle that emerges is that courts should seek expert assistance when technical or specialized questions arise, rather than attempting to resolve such questions through judicial pronouncement alone. This approach ensures that decisions are based on sound expertise while maintaining judicial oversight to prevent arbitrariness or mala fides. The Supreme Court’s direction in the present case to constitute an expert committee exemplifies this balanced approach, where the court facilitates expert examination while retaining supervisory jurisdiction over the process.

The composition of expert committees becomes crucial in ensuring credibility and acceptability of their recommendations. The Supreme Court’s specific direction that the committee examining Question 8 should include a Professor of English demonstrates the importance of matching expertise to the specific nature of the question under examination. Similarly, for questions involving legal principles, the inclusion of eminent law professors as domain experts ensures that the evaluation is conducted by persons with deep knowledge of the subject matter. This approach minimizes the risk of partisan evaluation while lending academic rigor to the examination process [1].

Judicial Service Examinations and the Paradox of Expertise

The present case presented a unique paradox where judges of the High Court, who are themselves legal experts with decades of experience in law, were reviewing questions designed to test the legal knowledge of candidates for judicial service. One might argue that if any court were qualified to directly evaluate the correctness of legal questions in an examination, it would be the High Court that conducts judicial service examinations and whose judges possess intimate knowledge of the law being tested. However, the Supreme Court rejected this seemingly logical proposition and held that even in such cases, the principle of deferring to domain experts should be maintained.

This apparent paradox can be resolved by understanding the different capacities in which courts function. When a High Court exercises administrative functions in relation to judicial service examinations, such as approving syllabi, setting questions, or vetting answer keys, it acts through specialized committees comprising judges and academic experts. These administrative decisions are made collectively, with the benefit of diverse expertise and deliberation. However, when the High Court sits in its judicial capacity to review these administrative decisions, it must maintain institutional separation and cannot simply substitute its judicial opinion for the collective expert judgment made administratively.

The Supreme Court’s insistence on referring matters to expert committees even in judicial service examinations serves several important purposes. First, it maintains the integrity of the examination process by ensuring that all challenges to answer keys are evaluated through a consistent and transparent mechanism rather than being decided on a case-by-case basis through litigation. Second, it prevents the creation of a precedent where individual judges, based on their personal understanding of law or language, could override the collective determination of examination authorities. Third, it recognizes that expertise in practicing or adjudicating law is different from expertise in designing and evaluating examination questions, which requires specific pedagogical knowledge and experience.

The decision also addresses the practical concern that if courts routinely intervene to correct answer keys based on their own assessment, it would incentivize candidates to litigate every disputed question rather than accepting the expert determination of examination authorities. This could lead to prolonged delays in finalizing results, create uncertainty for successful candidates, and undermine the credibility of the examination system. By establishing that courts should refer such matters to expert committees rather than deciding them directly, the Supreme Court has created a procedural safeguard that balances the need for accountability with the importance of finality in examination processes.

Balancing Rights of Candidates with Institutional Integrity

The Supreme Court’s decision raises important questions about balancing the rights of examination candidates with the need to maintain institutional integrity and respect for specialized expertise. Candidates who believe they have been unfairly marked due to errors in answer keys have a legitimate interest in seeking correction, particularly when success in competitive examinations can determine their career prospects. The right to equality and fair treatment, guaranteed under Article 14 of the Constitution, extends to examination processes and requires that candidates be evaluated fairly and according to correct standards.

However, the practical administration of examinations, particularly large-scale competitive examinations, requires some degree of finality and deference to the expertise of examination authorities. If every candidate could obtain judicial review of the correctness of every answer in every examination, the examination system would become unworkable. Courts must therefore strike a balance between ensuring fairness to individual candidates and maintaining the overall integrity and efficiency of the examination system. The Supreme Court’s approach in this case achieves this balance by providing a mechanism for expert re-examination of disputed questions while preventing courts from directly substituting their judgment for that of examination authorities.

The direction to constitute expert committees and complete the re-examination within two weeks demonstrates the Court’s sensitivity to the need for timely resolution of examination disputes. Prolonged uncertainty about results can cause significant hardship to candidates who may have planned their careers around the examination. At the same time, ensuring that the re-examination is conducted by properly constituted expert committees provides credibility to the process and addresses candidates’ concerns about fairness. This time-bound expert review mechanism may serve as a model for handling similar disputes in the future, providing a middle path between unlimited judicial intervention and complete insulation of examination authorities from accountability.

Implications for Administrative Law and Separation of Powers

The Supreme Court’s decision has broader implications for administrative law and the constitutional principle of separation of powers. The Indian Constitution establishes a system of checks and balances where the judiciary exercises supervisory jurisdiction over executive and administrative actions through the power of judicial review. However, this power is not unlimited and must respect the domain of expertise and authority vested in administrative bodies by the Constitution and statutes. The present decision reinforces the principle that judicial review should focus on legality, procedural fairness, and rationality rather than on the merits of decisions requiring specialized expertise.

Public Service Commissions, such as the JPSC, are constitutional bodies established under Article 315 of the Constitution with specific functions relating to recruitment to public services. These bodies are intended to function independently and bring specialized expertise to the recruitment process. While their decisions are subject to judicial review, courts must exercise this power with due regard to the constitutional role and expertise of these institutions. Excessive judicial intervention in the substantive decisions of such bodies could undermine their independence and effectiveness, contrary to the constitutional scheme.

The decision also reflects a growing recognition in Indian jurisprudence that effective governance requires specialized institutions with domain expertise, and courts should facilitate rather than replace the functioning of such institutions. This principle has been applied in various contexts, from technical regulatory matters to policy decisions requiring economic or scientific expertise. The emphasis on expert committees as an intermediary between administrative bodies and judicial review creates a framework where courts can ensure accountability while respecting specialized knowledge. This framework may be particularly relevant as governance becomes increasingly complex and technical, requiring courts to develop mechanisms for obtaining expert input without abandoning their supervisory role.

International Perspectives on Judicial Review of Examinations

The principle that courts should exercise restraint in reviewing academic and examination matters is not unique to India but finds resonance in legal systems around the world. In many jurisdictions, courts have developed doctrines of academic deference or educational judgment that limit judicial intervention in matters requiring educational or academic expertise. These doctrines recognize that educators and examination authorities possess specialized knowledge about pedagogy, assessment, and subject matter that courts typically lack. While the specific formulations vary across legal systems, the underlying principle remains consistent with the Supreme Court’s approach in the present case.

Common law jurisdictions have long recognized the limits of judicial review in examination matters, holding that courts should exercise restraint in interfering with academic decisions, including examination results, unless there is clear evidence of procedural irregularity, bias, or manifest error. This approach reflects both practical considerations about judicial competence in academic matters and policy concerns regarding the preservation of academic autonomy. At the same time, these jurisdictions have developed mechanisms to ensure fairness through internal review processes, ombudsmen, and appeals to academic bodies rather than resorting to courts. The Supreme Court’s direction to constitute expert committees in disputed examinations aligns with this international trend, providing robust non-judicial review mechanisms while maintaining credibility and fairness.

The use of expert committees or panels to assist courts in technical matters is also well-established internationally. Many legal systems provide for court-appointed experts who can provide specialized knowledge to assist judicial decision-making. The Council of Europe has developed detailed guidelines on the role of court-appointed experts, emphasizing the importance of expert independence, qualification, and transparency in expert examination. These international standards recognize that while courts remain the ultimate decision-makers, they must rely on expert assistance in matters beyond their competence. The Supreme Court’s approach in directing expert re-examination while retaining supervisory jurisdiction is consistent with these international best practices [7].

Practical Challenges in Implementation

While the Supreme Court’s decision establishes an important principle, its implementation may face practical challenges that need to be addressed through careful institutional design. The constitution of expert committees requires careful attention to issues of composition, methodology, independence, and transparency. Expert committees must be composed of persons with genuine expertise in the relevant field who are free from bias or conflict of interest. The criteria for selecting committee members, the procedures they should follow, and the standards they should apply in evaluating disputed questions all require careful consideration.

The question of what constitutes sufficient expertise and how to ensure diversity of academic opinion within expert committees presents another challenge. In the present case, the Supreme Court specifically directed that the committee examining Question 8 should include a Professor of English, recognizing the need for linguistic expertise. However, for questions involving debatable legal or academic principles, there may be legitimate differences of opinion among experts. The process must therefore provide for consideration of different expert views and establish clear standards for resolving disagreements within the committee.

Transparency in the functioning of expert committees is essential to maintain public confidence and ensure accountability. The committees should be required to provide written reports explaining their reasoning and the basis for their conclusions. These reports should address the arguments raised by candidates challenging the answer keys and explain why those arguments are accepted or rejected. Such transparency would enable judicial review if necessary while maintaining the principle that substantive academic judgment is made by experts rather than courts. It would also help develop a body of precedents and standards that could guide future examination processes and reduce the scope for disputes.

The time frame for expert committee examination is another practical consideration highlighted by the Supreme Court’s direction for completion within two weeks. While timely resolution is important, expert committees must be given sufficient time to conduct thorough examination, consult relevant materials, and deliberate carefully. The two-week timeline in this case was appropriate given that only three questions were under review, but for more complex cases or larger numbers of disputed questions, longer periods may be necessary. Examination authorities should develop standardized procedures and timelines for expert committee review to ensure consistency and predictability.

Conclusion

The Supreme Court’s decision in the Jharkhand Public Service Commission case represents a significant contribution to Indian administrative law and the jurisprudence on the scope and limits of judicial review in examination matters and specialized decisions. The Court’s emphatic declaration that High Courts cannot assume the role of super-examiners or subject experts, even in judicial service examinations, establishes an important principle of judicial restraint in matters requiring domain expertise. This principle balances the need for judicial oversight to prevent arbitrariness and ensure fairness with the recognition that courts should not substitute their judgment for that of specialized bodies and experts in technical matters.

The decision’s emphasis on referring disputed examination questions to expert committees rather than having courts directly determine correctness provides a practical mechanism for resolving such disputes while maintaining appropriate institutional boundaries. This approach respects the expertise of examination authorities and academic experts while ensuring that legitimate concerns about answer key errors can be addressed through a credible and transparent process. The framework established by this decision may serve as a model for handling similar disputes across various fields where courts must review decisions requiring specialized knowledge.

The broader implications of this decision extend beyond examination disputes to the general principles governing judicial review of administrative action. The decision reinforces the understanding that judicial review should focus on ensuring legality, procedural fairness, and rationality rather than on second-guessing the substantive merits of decisions made by bodies with specialized expertise. This principle is particularly important in an era of increasingly complex and technical governance, where effective administration requires reliance on specialized institutions and expert knowledge. Courts must develop mechanisms to ensure accountability while respecting the domain of expertise assigned to administrative bodies.

For examination candidates and authorities, the decision provides important guidance on the appropriate forums and procedures for challenging answer keys. Candidates retain the right to raise concerns about answer key errors, but such concerns should ordinarily be addressed through expert committees constituted for this purpose rather than through direct judicial determination in writ petitions. Examination authorities, for their part, must ensure that robust and transparent mechanisms exist for reviewing disputed answers, including the constitution of properly qualified expert committees and provision of reasoned decisions that can be subject to judicial review if necessary.

The Supreme Court’s decision serves as a reminder that the effectiveness of judicial review depends not on courts assuming expertise they do not possess, but on courts ensuring that decisions are made by appropriate bodies following fair processes and with proper application of relevant expertise. By directing expert re-examination while retaining supervisory jurisdiction, the Court has demonstrated how judicial review can be exercised in a manner that enhances rather than undermines the quality of administrative decision-making. This balanced approach respects both the constitutional role of courts in ensuring accountability and the institutional expertise necessary for effective governance in specialized domains.

As India continues to develop its administrative law jurisprudence, this decision will likely be cited as an important precedent establishing the limits of judicial review in matters requiring specialized knowledge. The principle that courts should ordinarily leave such matters to domain experts while ensuring procedural fairness and accountability through institutional mechanisms represents a mature understanding of the respective roles of judiciary and administration in constitutional governance. The challenge ahead lies in implementing this principle through effective institutional design that maintains public confidence while respecting expertise, ensuring fairness while avoiding excessive litigation, and upholding accountability while preserving administrative efficiency.

References

[1] Jharkhand Public Service Commission v. The State of Jharkhand, C.A. No. 001455/2026, Supreme Court of India (February 11, 2026). Available at: https://www.livelaw.in/pdf_upload/2026/02/11/5026920252026-02-09-1-655484.pdf 

[2] Jharkhand High Court order in writ petition challenging JPSC answer key (2024). Available at: https://www.livelaw.in/high-court/jharkhand-high-court/jharkhand-hc-3-jpsc-model-answer-incorrect-civil-judge-exam-direct-jpsc-award-marks-recompute-final-merit-list-290474 

[3] Ramesh Chandra Agarwal v. Regency Hospital Ltd., Supreme Court of India. Available at: https://www.mondaq.com/india/civil-law/247286/relevancy-of-expert-opinion-before-court 

[4] National Board of Examination v. Association of MD Physicians, Delhi High Court. Available at: https://lawbeat.in/amp/top-stories/judges-are-not-and-cannot-be-experts-all-fields-cant-supplant-expert-opinion-delhi-high-court 

[5] The Indian Evidence Act, 1872, Section 45 and Section 39 of the Bharatiya Sakshya Adhiniyam. Available at: https://www.apnilaw.com/legal-articles/acts/section-45-of-the-indian-evidence-act-vs-section-39-of-the-bharatiya-sakshya-adhiniyam-expert-evidence-and-opinions-of-experts-explained/ 

[6] S. Gopal Reddy v. State of A.P., Supreme Court of India. Available at: https://www.lawctopus.com/clatalogue/clat-pg/expert-opinion-under-indian-evidence-act/ 

[7] Council of Europe Guidelines on Court-Appointed Experts in Judicial Proceedings. Available at: https://rm.coe.int/168074827a 

[8] Bal Krishna Das Agarwal v. Radha Devi, Supreme Court of India. Available at: https://www.mondaq.com/india/trials-amp-appeals-amp-compensation/1258928/examination-of-expert-opinion-relevancy-admissibility-and-the-framework 

[9] State of Karnataka v. J. Jayalalitha, Supreme Court of India. Available at: https://www.legalserviceindia.com/legal/article-1583/experts-opinion-and-its-admissibility-and-relevancy-law-of-evidence.html