Regulation 39(2) of CA Regulations, 1988: Revision of Marks Explained#
In terms of Regulation 39(2) of the Chartered Accountants Regulations, 1988, the Institute of Chartered Accountants of India (ICAI) has the power to revise marks — which, in theory, may include increase or decrease in the marks scored by candidates.
📜 Regulation 39(2) – Extract#
39. Examination results
(2) The Council may, in its discretion, revise the marks obtained by all candidates or a section of candidates in any particular paper or papers or in the aggregate in such manner as may be considered necessary, for maintaining the standards of pass percentage provided in these Regulations.
Explanation:
The term “section” used in this sub-regulation refers to the category of candidates whose answer papers are valued by an examiner and such other category of candidates as may be specified by the Council.
Common Doubt Among Students#
A few students who received certified copies of answer sheets under RTI observed that the marks written inside the answer book were lower than the marks declared in the final result. This led to confusion and concern as to whether:
Have my marks been decreased during verification?
Clarification: Answer Book Marks vs Result Marks#
It is important to clearly understand the distinction:
Marks in the answer book
→ These are the actual marks awarded by the examiner based purely on the candidate’s performance.Marks declared in the result / mark sheet
→ These include revised marks awarded under Regulation 39(2), wherever applicable.
Therefore, a difference between answer book marks and result marks does not indicate a reduction.
Does ICAI Reduce Marks Under Regulation 39(2)?#
Although Regulation 39(2) empowers ICAI to revise marks, there are no reported instances where ICAI has reduced the actual marks scored by students under this regulation.
On the contrary:
- ICAI has awarded grace marks (increase) to candidates
- Such increases are made based on recommendations of the Head Examiner
- The objective is to maintain uniformity and fairness in pass percentage
RTI Reply Confirming Addition of Marks#
In response to an RTI Application dated 4th February 2020, a reply was received on 5th March 2020, wherein ICAI provided subject-wise details of marks added by the Examination Committee under Regulation 39(2).
The RTI reply clearly shows:
- Marks added (not reduced)
- Data for May 2019 and November 2019
- Applicable to CA Final and IPCC / Intermediate examinations
Extract of RTI Reply (For Reference)#

Conclusion#
- Regulation 39(2) allows revision of marks for maintaining standards
- Actual marks in answer books are never reduced
- Any difference usually reflects grace marks added
- RTI replies and official data confirm only upward revision
Students should therefore not panic if answer book marks appear lower than result marks. The final declared result already incorporates revisions made in the interest of fairness and consistency.
Transparency through RTI continues to help students understand the evaluation process better.


