The Delhi High Court has reaffirmed that judicial interference in medical fitness determinations for disciplined services must be exceptional, and that independently obtained medical certificates cannot override the unanimous findings of two duly constituted Medical Boards. This judgment clarifies the limits of judicial review in recruitment processes governed by strict statutory standards.
Background & Facts
The Dispute
The dispute arose from the Staff Selection Commission’s (SSC) recruitment process for the post of Constable (Executive), wherein the Respondent, Yashpal Singh, was declared medically unfit after undergoing both the Detailed Medical Examination (DME) and the Review Medical Examination (RME). The Respondent challenged this finding before the Central Administrative Tribunal (CAT), relying on a medical certificate issued by a Government Hospital, which stated he was fit for competitive examinations. The Tribunal allowed his claim and directed a fresh medical examination by a newly constituted Medical Board. The SSC challenged this order before the Delhi High Court.
Key Facts
- The Respondent participated in SSC’s recruitment process under Advertisement dated 01.09.2023, governed by the Delhi Police (Appointment and Recruitment) Rules, 1980.
- He underwent DME on 25.01.2024, where the Medical Board found him suffering from Varicose Veins in the left leg and declared him medically unfit.
- He requested RME, which was conducted on 31.01.2024; the Review Medical Board independently concurred with the DME’s findings.
- On 30.03.2024, the Respondent obtained a medical certificate from a Government Hospital stating he was "medically fit to participate in competitive or non-competitive examinations."
- This certificate did not specifically address fitness for the post of Constable (Executive) in Delhi Police.
- The Respondent did not challenge the Advertisement, Standing Order dated 08.06.2022, or Rule 24(2) of the 1980 Recruitment Rules.
Procedural History
- 25.01.2024: DME conducted; Respondent declared medically unfit.
- 31.01.2024: RME conducted; findings confirmed.
- 30.03.2024: Respondent obtained independent medical certificate from Government Hospital.
- 15.07.2024: Original Application (O.A. No. 1547/2024) filed before Central Administrative Tribunal.
- 20.08.2024: Tribunal allowed the OA and directed a fresh medical examination by a new Medical Board.
- 28.08.2024: Petition filed before Delhi High Court under Article 226.
- 25.02.2026: Judgment reserved.
- 16.03.2026: Judgment pronounced.
The Parties' Positions
Petitioner (SSC): Argued that the Tribunal exceeded its jurisdiction by substituting its opinion for that of expert Medical Boards. Emphasized that the DME and RME were conducted in strict compliance with the 1980 Recruitment Rules and that independent certificates cannot override them.
Respondent (Yashpal Singh): Contended that the Government Hospital’s certificate raised a reasonable doubt about the DME and RME findings and that fairness demanded a fresh examination.
Relief Sought
The Petitioner sought quashing of the Tribunal’s order dated 20.08.2024 and restoration of the original medical fitness determination. The Respondent sought enforcement of the Tribunal’s direction for a fresh medical examination.
The Legal Issue
The central question was whether an independently obtained medical certificate from a Government Hospital, contradicting the unanimous findings of two duly constituted Medical Boards under the recruitment rules, constitutes a valid ground for directing a fresh medical examination in recruitment to disciplined services.
Arguments Presented
For the Petitioner
The Petitioner relied on Staff Selection Commission & Ors. v. Aman Singh to argue that judicial review in medical fitness matters is strictly limited. The DME and RME were conducted in accordance with the 1980 Recruitment Rules, particularly Rule 24(2), which permits rejection if a candidate suffers from a condition likely to interfere with efficient duty performance. The certificate dated 30.03.2024 was a general fitness statement, not specific to the post, and was procured without any reference from the Medical Boards. The Petitioner further cited Indian Council of Agricultural Research v. Shashi Gupta to emphasize that courts must defer to expert medical opinions absent arbitrariness, procedural irregularity, or lack of specialist input.
For the Respondent
The Respondent relied on Vijay v. Union of India and Teekaram Singh Meena v. SSC to argue that where conflicting medical opinions exist, fairness requires a fresh examination. He contended that the Government Hospital’s certificate, being from a public institution, carried sufficient weight to cast doubt on the Medical Boards’ findings and warranted judicial intervention to ensure equity.
The Court's Analysis
The Court began by affirming the settled principle that medical fitness determinations for disciplined services like police are entrusted to expert Medical Boards constituted under statutory rules. Courts must exercise restraint and not substitute their own opinion for that of these bodies, as held in Shashi Gupta and reiterated in Aman Singh.
"The function of the Court can only, therefore, be to examine whether the manner in which the candidate was assessed by the Medical Boards, and the conclusion which the Medical Boards have arrived, inspires confidence, or transgresses any established norm of law, procedure or fair play. If it does not, the Court cannot itself examine the material on record to come to a conclusion as to whether the candidate does, or does not, suffer from the concerned ailment."
The Court noted that the DME and RME were conducted on two separate occasions by independent boards, both arriving at the same conclusion: the Respondent suffered from Varicose Veins, a condition falling within the disqualifying criteria under Rule 24(2). There was no discrepancy between the two findings, no procedural irregularity, and no indication that the Boards lacked specialists qualified to assess the condition.
The Court emphasized that the certificate dated 30.03.2024 was obtained by the Respondent on his own initiative, without any referral from the Medical Boards. It was a general certificate, not tailored to the specific physical demands of a Constable (Executive) in Delhi Police. The Court held that permitting such certificates to override unanimous expert findings would undermine the integrity and finality of the recruitment process.
The Court distinguished Vijay and Teekaram Singh Meena, noting that in those cases, the medical records revealed procedural gaps or specialist deficiencies absent here. The Court also clarified that the issue of curability or general fitness is irrelevant unless the Medical Boards themselves had referred the candidate for further evaluation or the rules explicitly permitted reconsideration.
Finally, the Court underscored that the determination of whether Varicose Veins renders a candidate unfit for police service is a matter exclusively within the domain of the recruiting authority and its expert boards, not the judiciary.
The Verdict
The Petition was allowed. The Delhi High Court set aside the Tribunal’s order dated 20.08.2024 directing a fresh medical examination. The original medical fitness determination by the DME and RME dated 25.01.2024 and 31.01.2024 stands affirmed. The Respondent’s application for appointment is deemed rejected on medical grounds. No costs were awarded.
What This Means For Similar Cases
Independent Medical Certificates Are Not Dispositive
- Practitioners must advise clients that general medical certificates from hospitals, even government ones, cannot override the findings of two independent Medical Boards under recruitment rules.
- Such certificates may be submitted as supplementary material but cannot trigger a right to re-examination unless procedural flaws or specialist deficiencies are proven.
Concurrence of Medical Boards Is a Strong Presumption
- When DME and RME concur on the existence of a disqualifying condition, courts will not interfere absent evidence of arbitrariness, procedural breach, or lack of specialist input.
- Candidates cannot reopen medical assessments merely because they obtained a contrary opinion after the fact.
Judicial Restraint in Disciplined Services Recruitment
- Courts must avoid substituting their judgment on medical fitness, especially for roles involving public safety.
- The burden remains on the candidate to demonstrate a clear procedural or substantive flaw in the Medical Board’s process - not merely to present a conflicting opinion.
The Role of Rule 24(2) of the 1980 Recruitment Rules
- Rule 24(2) remains a valid and enforceable standard for disqualification.
- Conditions like Varicose Veins, if deemed likely to interfere with duty performance, are within the recruiting authority’s discretion to disqualify.
No Automatic Right to Re-examination
- The existence of an RME mechanism is not a second chance to become fit; it is a review of the initial assessment.
- Candidates must comply with the process as advertised and cannot seek deviations after failure.
