5 min readAhmedabadUpdated: Aug 17, 2026 06:16 PM IST
An academic debate over whether Kautilya’s Arthashastra is a book on economics cost a Gujarat Public Service Commission (GPSC) candidate a crucial mark, leaving her 1.23 marks short of the cut-off for the Sales Tax Inspector examination in 2024.
The Gujarat High Court has now directed GPSC to restore the deducted mark and consider Arati Rangpariya for the select or waiting list as if she had cleared the preliminary exam. Justice Nirzar Desai struck down the commission’s key, holding that its answer was based on “unauthenticated” material downloaded from an unknown internet source. The court also rejected GPSC’s plea for a four-week stay.
Rangpariya appeared for the preliminary examination for Sales Tax Inspector, Class III, on December 22, 2024. She was allotted Series B of the question paper. She scored 94.36 marks in the Economically Weaker Section (EWS) category, against a cut-off of 95.59 for the Mains examination.
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As per the petition, Question No. 147 presented two statements: that Arthashastra was written in Sanskrit and that it was a book of economics. The final answer key treated only the first statement as correct. Rangpariya argued that both were correct and that Option C (selecting both statements as correct) should therefore have been accepted.
Senior Advocate Megha Jani, appearing for the petitioner, emphasised that the material from the Gujarat state school Class 11 Economics textbook referred to Kautilya’s economic thought and his Arthashastra. The petitioner also relied on the Gujarat Council of Educational Research and Training (GCERT) and the National Council of Educational Research and Training (NCERT) textbooks, which are widely used by candidates preparing for competitive examinations.
GPSC, however, relied on an English translation of the Arthashastra attributed to R Shamasastry. It maintained that although the work covered economics, it could not be described as a book exclusively about economics. Its expert opinion, the commission said, regarded the work as principally concerned with politics and administration.
Commission that couldn’t produce its own source
What began as a routine answer-key dispute turned, over eight hearings between March and July 2026, into a pointed examination of how GPSC frames its questions. After the commission’s paper-setter admitted that the “original book is not available” and could not say where the PDF had been downloaded from, the High Court even came close to initiating contempt proceedings twice, calling one GPSC affidavit “merely an eyewash”.
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The commission’s own affidavit conceded that Arthashastra “does cover the subject of economics,” even as it argued the book was not exclusively about economics. Government Pleader G H Virk cited Supreme Court rulings to argue courts must show extreme restraint before disturbing an expert-vetted answer key, and that any doubt should benefit the examining authority, not the candidate.
Advocate Jani countered that this deference presumes an authenticated source in the first place. She pointed out that GPSC’s own affidavits cited Amazon and Slideshare as sources from which the 1915 edition, translated by R. Shamasastry, could be obtained, with no publisher name or date verifiable on the pages GPSC placed on record.
Not merely about correctness of answer
The judgment states that the court examined the downloaded PDF, noting that Kautilya’s own text describes the Arthashastra as “a compendium of almost all the Arthasastras… composed by ancient teachers” across 15 constituent books, undercutting GPSC’s claim that a single, narrow “broadly accepted understanding” was enough to frame a definitive answer.
“It is not merely a case about the correctness of the answer because the source from which the question is asked, itself, is admittedly from an unknown source on the internet,” the judge held.
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The court added that GPSC had “no policy in writing to authenticate the downloaded reference material,” and that in general-awareness papers –as opposed to subject-specific ones–any resulting doubt “must go to the students… and not to the examining body”.
The court also highlighted the issue of the source’s age, noting that it was “absolutely unreasonable” to expect candidates, most of whom were in their thirties, to locate a PDF of an 111-year-old edition without any verifiable original. This expectation was inconsistent with the Supreme Court’s own standard, which holds that a key answer should be presumed correct only if it is demonstrably authenticated.
Restoring the candidature
The court noted that the relief was confined to Rangpariya alone since no other candidate among those who had earlier moved allied petitions pursued the challenge once results were declared. Notably, she was the only petitioner among the group of connected cases to have separately cleared the Mains examination while the litigation was pending.
The commission subsequently acknowledged in an affidavit that the paper-setter had relied on a digital PDF available as part of his academic resources, but that GPSC did not know where he had downloaded it. More significantly, GPSC admitted that it had no written policy governing authentication of material relied upon by a candidate or paper-setter.
