Simplified Explanation of the Judgment

This case arose from the selection process for constables in the Central Armed Police Forces, conducted through the Staff Selection Commission (SSC). The petitioner, a female candidate, had cleared the physical efficiency test but was later declared medically unfit in January 2020 by a medical board on four counts:

1. Overweight
2. Deficiency of Vision (DOV-N-8)
3. Pes cavus (a foot deformity)
4. Abnormal chest X-ray showing broncho-vascular markings

The petitioner challenged this decision by filing an appeal for a Review Medical Examination as permitted under the recruitment rules. However, her appeal was rejected because the medical certificate she submitted was not signed by a “Specialist Medical Officer of the concerned field,” which was a mandatory requirement. Instead, her certificate was signed by a Deputy Superintendent-cum-Assistant Additional Chief Medical Officer from a district hospital, who was not recognized as a specialist in any of the deficiencies noted.

The petitioner argued that:

• The recruitment rules did not explicitly require a “specialist’s” opinion.
• The deficiency of vision (DOV-N-8) was wrongly recorded, as her original memorandum showed “DOV-N-0,” which, according to a later medical opinion, did not relate to eyesight.
• She was given only one Form No.3 (for medical certification), despite being declared unfit on four grounds, making it impossible to provide four separate specialist certificates.

The respondents (SSC, CRPF, and Union of India), represented by the Additional Solicitor General, countered that:

• The requirement of a specialist’s certificate was clearly mentioned in the memorandum of unfitness (Annexure-6) and Form No.3.
• The petitioner’s doctor had written “NIL” in the column where he was supposed to record reasons showing an error in the initial medical board’s assessment. This meant the certificate did not support her appeal at all.
• The claim about “DOV-N-0” being wrongly mentioned was an afterthought, raised for the first time during the court proceedings.

The Patna High Court, after examining the records, sided with the respondents. The Court noted:

• The requirement of a specialist medical certificate was clearly stated in both the rejection memorandum and Form No.3.
• The petitioner knowingly submitted a certificate from a non-specialist, which did not satisfy the conditions.
• The certificate was defective because the doctor failed to give any opinion on whether the first medical board’s decision was erroneous. Writing “NIL” in the remarks section meant no grounds for review existed.
• The petitioner’s claim regarding only one form being supplied was not raised at the time of appeal and appeared to be an afterthought.
• Since the recruitment was for a paramilitary force (CRPF), physical fitness standards had to be strictly applied because duties would involve severe and demanding conditions.

Accordingly, the Court dismissed the writ petition, holding that the rejection of her review medical request was valid and in line with the rules.

Significance or Implication of the Judgment

• For Candidates: This case highlights the importance of carefully following medical review guidelines in recruitment. Submitting certificates from authorized “specialist” doctors is mandatory; failure to comply can lead to dismissal of appeals.
• For SSC and CAPFs: The judgment reinforces strict adherence to recruitment standards for armed forces where physical fitness is critical for national security and operational effectiveness.
• For Public: It reflects the judiciary’s support for maintaining rigorous physical standards in paramilitary forces, ensuring that only medically fit candidates are selected.

Legal Issue(s) Decided and the Court’s Decision

• Whether a review medical appeal can be accepted without a certificate from a specialist doctor?
  – Decision: No. The rules and Form No.3 explicitly require certification by a specialist in the concerned field.
• Whether the candidate’s plea about errors in recording vision deficiency (DOV-N-0 vs. DOV-N-8) was valid?
  – Decision: The Court found it an afterthought, as no such objection was raised during the review stage.
• Whether strict physical standards for CRPF recruitment can be relaxed?
  – Decision: No. The Court emphasized that CRPF duties are highly demanding, and strict fitness requirements must be enforced.

Judgments Relied Upon or Cited by Court

• The Court primarily relied on the recruitment scheme itself (Constable GD Exam-2018 guidelines, Clause 9E) rather than external judgments.

Case Title

Petitioner vs. Staff Selection Commission & Ors.

Case Number

CWJC No. 8698 of 2020

Citation(s)

2021(1)PLJR 737

Coram and Names of Judges

• Hon’ble Mr. Justice Madhuresh Prasad (Oral Judgment, 01-12-2020)

Names of Advocates and who they appeared for

• For Petitioner: Mr. Arun Kumar, Advocate
• For Union of India: Mr. K.N. Singh, ASG with Mr. Kumar Sachin, CGC
• For SSC: Mr. Rajesh Kumar Verma, ASG

Link to Judgment

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