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20. Subsequently, relying on Lila Dhar (supra) and Ashok Kumar Yadav (supra), the Supreme Court in Anzar Ahmad (supra) held that 50 percent weightage to academic marks and 50 percent marks for interview does not suffer from the vice of arbitrariness. Relevant paragraphs are delineated below:

"14. These observations would indicate that the matter of weight to be attached to interview and the allocation of marks for interview vis-a-vis marks for written examination can arise when written examination as well as viva voce test are both accepted as essential features of proper selection and there also no hard and fast rule regarding the precise weight to be given to the viva voce test as against written examination, can be laid down and the said weight must vary from service to service according to the requirement of the service. The question of weight to be attached to viva voce would not arise where the selection is to be made on the basis of interview only. In Ashok Kumar Yadav case [(1985) 4 SCC 417 : 1986 SCC (L&S) 88 : 1985 Supp 1 SCR 657] this Court has held that in the case of ex- service officers viva voce test may be attached relatively greater weight because the personalities of such officers being fully mature and developed it would not be difficult to arrive at a fair assessment of their merits on the basis of searching and incisive viva voce test. But at the same time the Court felt that the allocation of 33.3% marks for viva voce test for ex-service officers and 22.2% for other candidates was excessive and that the same should not exceed 25% for ex-service officers and 12.2% for other candidates.
22. It is difficult to accept the omnibus contention that selection on the basis of viva voce only is arbitrary and illegal and that since allocation of 15% marks for interview was held to be arbitrary by this Court, selections solely based on interview is a fortiori illegal. It will be useful to bear in mind that there is no rule of thumb with regard to allotment of percentage of marks for interview. It depends on several factors and the question of permissible percentage of marks for an interview-test has to be decided on the facts of each case. However, the decisions of this Court with regard to reasonableness of percentage of marks allotted for interview in cases of admission to educational institutions/schools will not afford a proper guidance in determining the permissible percentage of marks for interview in cases of selection/appointment to the posts in various services. Even in this class, there may be two categories: (i) when the selection is by both a written test and viva voce; and (ii) by viva voce alone. The courts have frowned upon prescribing higher percentage of marks for interview when selection is on the basis of both oral interview and a written test. But, where oral interview alone has been the criteria for selection/appointment/promotion to any posts in senior positions the question of higher percentage of marks for interview does not arise. ..........."

24. Supreme Court in the earlier judgment of Lila Dhar (supra) held that a written test assesses man's intellect and the interview test the man himself and in cases where selection is to be made out of mature persons, a higher weightage may be given to the viva-voce test. In the case of Mehmood Alam Tariq and Others -v- State of Rajasthan and Others reported in AIR 1988 SC 1451 [Coram: Ranganath Misra and M.N. Venkatachaliah, JJ.], Supreme Court accepted the 33% marks that was allotted for viva-voce with the reasoning that the officials to be selected for higher services would be required "to man increasingly responsible positions in the core services" and hence it is to be tested whether these men possess the personality traits according to the level of performance in such interviews. Similarly, 35% marks allocation for viva-voce for selection for judicial branch was upheld in the case of State of Uttar Pradesh -v- Rafiquddin and Others reported in AIR 1988 SC 162 [Coram: E.S. Venkataramiah and K. N. Singh, JJ.]. In the case of Indian Airlines Corporation -v- Capt. K.C. Shukla and Others reported in 1993(1) SCC 17 [Coram: S. Ratnavel Pandian and R.M. Sahai, JJ.], Supreme Court pointed out that a distinction is there in interviews held for competitive examination or admission in educational institution or selection for higher posts and a particular percentage cannot be decided for viva-voce, there cannot be any hard and fast rule about it and it depends on the level of post and the nature of performance expected from the candidate. Furthermore, as noted in Anzar Ahmad and Ors. (supra) even 50% weightage in academic marks and 50% for interview does not suffer from the voice of arbitrariness. Moreover, in Kiran Gupta and Ors. (supra) the Supreme Court has categorically held that there may be certain cases where the mode of selection may be only on the basis of interview and in such situations the question of percentage of marks awarded for the interview does not arise at all. On an examination of the abovementioned judgments of the Supreme Court, it becomes clear that no hard and fast rules can be applicable for deciding on the percentage of marks to be awarded for a viva-voce. Each case has to be decided keeping in mind various factors.