The protest, led by a few teaching members, aims at making ICAI amend Regulation 39(4) which permits only re-totalling of answer papers.

CA students to protest against ICAI Why they are demanding the right of revaluation Twitter/@theicai
news Education Tuesday, December 25, 2018 - 18:32

Students across the country are getting ready to raise their voices against their certifying authority, the Institute of Chartered Accountants of India (ICAI), which is the second largest professional accounting body in the world. Students and a few teachers allege that there have been instances of errors in the evaluation of the examination and are demanding that the ICAI amends Regulation 39(4) of the CA Regulations, 1988.

Though initially the protests, in the form of silent assembly and a hunger strike, were supposed to take place across the country from Wednesday, the students and the faculty members who are leading are considering postponing the same.

The seed to protest came after CA Parveen Sharma published a video on September 8, which showed that a student had not been awarded the marks they deserved. In the video, Parveen compared the inspected answer sheet with the suggested answers published by the ICAI for that exam. In the answer paper, though the student had given the correct answer for a question, the examiner had awarded zero marks against the same. This drill was consistent for all the answers written by that student, except the very first question, for which the examiner had awarded three marks. In the end, the student failed the paper as they earned a single digit mark, even though the answers deserved much more than what was awarded. However, according to ICAI rules, the paper will not be re-evaluated.

This video became viral in a matter of hours, leading the students to realise the gravity of the situation. Amply supported by other popular faculty members in North India, the message spread across the community about the unfair regulations. The demand of the students is for the institute to permit revaluation of answer papers. This could be a step towards bringing in transparency in the process, they say.

The students also took to Twitter to express their demands and soon, #amend394 became a trending hashtag.

Parveen also sent a letter to the institute, detailing the flaws in the evaluation process and the urgent requirement for reforms. He is part of the group protesting the process, and in another video, informed that the decision to hold protests was taken due to the lack of response from ICAI on the letter sent by him.

Regulation 39(4)

The Chartered Accountants Act of 1949 and the Chartered Accountants Regulation of 1988 govern the professional lives of the chartered accountants and CA students in India. As per the clauses in the CA regulations, once the results of the CA examinations are published, the students are allowed to apply for re-totalling of their marks on payment of a fixed fee. This fee, however, is only to check if the student’s answers have been examined and marked, and not for re-examining the answers itself. The ICAI checks only for errors on the arithmetical accuracy of marks and omission to evaluate, and not the merits of awarding specific marks to a specific question.

“The fee shall be only for verifying whether the candidate's answers in any particular paper or papers have been examined and marked, and not for the re-examination of the answers,” reads a portion of the clause 39(4).

This is further clarified by the ICAI on its website where it is stated that it does not permit revaluation of answer books.


The impact of such a rule was that this particular student cannot use the copy of his or her own answer paper to demand a revaluation of answers by the institute. It is the merit of the awarded marks that were to be questioned there, to which the student is not entitled to, as per the existing norms of the ICAI.

Students keep failing their exams and were unable to understand what the examiners expected, which adversely affected their careers. Janani*, a student who attempted her CA final exams for the fifth time in November, says that this lack of transparency affects the morale of students, as well as their careers. “Beyond a certain number of attempts, students are not even considered to sit for job interviews. I think this is not fair, because the ICAI deprives the student of asking for revaluation, which leads to an increase in attempts. But then, the same ICAI does not regulate the unreasonable demands put forth by recruiters like the upper cap on the number of attempts when searching for a candidate.” 

Flaws in process 

Speaking to TNM, all-India rank holder and GST expert Mayank* says that whatever the institute claims to do to address the situation is not enough. “A lot of CAs who are given the task of correcting answer papers are not familiar with the subject they are assigned to evaluate. The criteria to enroll as an examiner with the ICAI are pretty basic. They just need to have a certain number of years experience as a qualified CA,” he says.

This point is reiterated by Shriram, a practicing CA from Chennai, who adds that examiners are not required to be subject experts when applying to be an examiner.

“The people who grade the papers need not be faculty members who remain in touch with the paper. In fact, people who take classes are not permitted to be examiners. The ones who are permitted need not have a thorough knowledge of the subject as much as an academician would have. The examiners need not necessarily be academicians,” he says adding that the requirement put forward by the students is genuine, basically because of the subjectivity involved in the process.

Shriram also adds that since the examiners correct the answer sheets in different places, there is no easy and faster avenue to discuss or debate an issue that is in the question paper or in answer sheets. “This issue crops up because fundamentally, people take a stand in their examination, be it the student or the valuer. Then there is subjectivity involved and there is a scope for debate,” he says

“Valuation is a subjective assessment, especially for questions that have multiple answers based on the assumptions made by students in answering that question,” he explains.

Shriram recommends a centralized evaluation in which examiners can sit in one place and do the valuation for a specified period of time and close the process. “Such an arrangement will opened up an arena for people to discuss and debate on contradictions in answers or assumptions made by students. If there is anything to be referred, the examiners can refer between themselves and zero in on a solution.”

What ICAI has to say

ICAI President CA Naveen ND Gupta, in a video published on December 21, acknowledged that this demand for a revamp in the process of evaluation is a long-standing one.

“We are working on the best practices on the revaluation of answer books which has been a long-standing demand but the same will require amendment in the CA Act and Regulations,” he said.

He also stated that the institute is in talks with the University Grants Commission (UGC), Ministry of Human Resources and Development (MHRD) and Ministry of Corporate Affairs (MCA) to take this forward for an amendment in the Act. But this assurance has failed to strike a chord.

“The ICAI prohibits students who get a copy of their inspected answer sheets to share those papers with anybody else. The President, in his December 21 speech, said that the ban had been scrapped in September. But then, the same institute used that ban to argue in the court in relation to a case in court in November. If it was scrapped in September as claimed by the President, then they could not have used it in the court. Actions like these are why the students don’t trust the ICAI or its claims of looking into the students’ demands to revamp the revaluation process,” says Johnson*, a student.

Is there a solution?

While the students want ICAI to be transparent in their evaluation process, other stakeholders also hope the institute make the course student-friendly. “The CA course must be tough because of the standard of the syllabus and the level of expertise it expects from the students and not because of the flawed evaluation process,” says Janani, adding that she is all for ICAI to raise the bar when it comes to the content of the course.

Mayank, however, wants the institute to hear students voices in the affairs of the institute. CA students -- who contribute a lion’s share to the revenue of the institute every year -- have no say in who governs them since only qualified members are allowed to vote in Regional and Central council elections.

“Students have no representation or redressal mechanism which means that if they have to complain about ICAI, they have to go to ICAI, which is not right. There is a conflict of interest because the institute is responsible for monitoring its own members and students. Every CA will tell that in any organisation there must be a separation of makers and checkers, but ironically this logic does not apply to ICAI,” he adds.

Shriram says that in his opinion, the students must not be stuck inside the system and that ICAI could very well take other global accounting courses like Association of Chartered Certified Accountants (ACCA) as an example in recognising the efforts of the students.

“For example, in ACCA, once the first stage is completed, the student is given the recognition of ‘Diploma in Accounting and Business’. Passing second stage of ACCA gives him a B.Sc in Accounting and Business and the final stage earns him the ACCA title. That is a very clear branding, which helps the student with some recognition in the job market if he or she decided to drop out of the course for various reasons. But in CA, even if a student completes the first stage and the articleship of three years and then opts to drop out, he or she is a dropout. It does not give them any value from companies in the job market,” he explains.

*Names have been changed on request

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