Facts
The petitioner had applied for appointment to the post of Forest Ranger pursuant to the Chhattisgarh Forest Service (Combined) Examination, 2020.
Source reference: no citationHe was required to appear in the Physical Efficiency Test (Walking), but allegedly suffered injuries in an accident before the scheduled test and was consequently unable to participate.
Source reference: no citationHe claimed to have informed the concerned authorities through applications/intimations dated 4 September 2023 and 11 September 2023, prior to the test date.
Source reference: para. 2; para. 5The petitioner previously filed WPS No. 4901 of 2024, which was disposed of on 16 August 2024 with liberty to submit a representation to the competent authorities.
Source reference: para. 2His subsequent representation dated 20 August 2024 was rejected by order dated 7 October 2025.
Source reference: para. 2He therefore filed the present writ petition seeking quashing of the rejection order and a further opportunity to undertake the Physical Efficiency Test.
Source reference: para. 2He also asserted that posts of Forest Ranger remained vacant.
Source reference: para. 2The respondents contended that no rule, statutory provision, or government circular authorised extension of the date fixed for the Physical Efficiency Test or permitted a re-test.
Source reference: para. 3Issues
Whether the petitioner, who was unable to appear in the Physical Efficiency Test due to an accident and had informed the authorities before the scheduled test, was entitled to a further opportunity to participate in the test?
Source reference: paras. 5–7Whether the absence of a specific rule, statutory provision, or circular providing for extension or re-testing barred the petitioner from being granted such an opportunity?
Source reference: paras. 3, 7Law Applied
The Court relied on the principle laid down by the Supreme Court in Mahendra Pratap Singh and Others v. State of Uttar Pradesh and Others, (2019) 13 SCC 706, wherein candidates who had informed the authorities of their ailment on or before the date of the Physical Efficiency Test were permitted to approach the competent authority with supporting material, with consequential action to be taken in accordance with the earlier decision in State of U.P. and Others v. Sudhakar Pandey, 2014 SCC OnLine All 16518.
Source reference: para. 6The applicable principle was that a candidate who was prevented from appearing in a physical test by a genuine medical condition and had timely informed the authorities could be considered for a re-test, subject to verification and the applicable recruitment requirements.
Source reference: no citationThe Court also considered the continuing availability of vacancies as a relevant circumstance.
Source reference: para. 7Reasoning
The Court found that the petitioner had sustained injuries in an accident before the scheduled Physical Efficiency Test and had claimed to have promptly informed the authorities through communications dated 4 September 2023 and 11 September 2023.
Source reference: para. 5The State did not dispute that such intimation had been given.
Source reference: para. 7Applying the principle in Mahendra Pratap Singh, the Court held that timely intimation of the medical impediment entitled the petitioner to consideration for a further test.
Source reference: no citationAlthough the respondents argued that no specific rule permitted extension of the test date, the Court treated the Supreme Court’s precedent and the undisputed prior intimation as sufficient grounds for relief.
Source reference: no citationThe petitioner’s assertion that Forest Ranger posts remained vacant further supported granting the limited relief without directing appointment or bypassing the selection process.
Source reference: para. 7Holding
The writ petition was allowed.
The respondents were directed to conduct the Physical Efficiency Test of the petitioner and thereafter proceed in accordance with law within 60 days from the date of receipt of a copy of the order.
Source reference: para. 7The Court thereby granted the petitioner a further opportunity to participate in the test, but did not direct his appointment or confer any automatic right to selection.
Source reference: para. 7; para. 8Original Court PDF
YOGESH BANJAREvsSTATE OF CHHATTISGARH
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