Binding Nature of Independent Medical Board Reports Over Internal Medical Opinions in Recruitment Disputes

The applicant was selected for the post of Assistant Loco Pilot (ALP) in 2022 but was declared medically unfit in the "Aye-One" category by a private hospital report, alleging a prior refractive procedure

In a previous round of litigation (OA No. 321/2023), the Tribunal directed a re-examination by a Government Hospital

Consequently, the SCB Medical College Board examined the applicant and concluded that there was no evidence of refractive surgery and his vision was sufficient for the post

Despite this, the Chief Medical Superintendent (CMS), SECR, Bilaspur, issued a fresh rejection order dated 06.02.2025, maintaining the applicant was unfit based on the CMS's personal opinion and the absence of a 'pachymetry' test in the Board's report

1. Whether the respondent authorities were justified in overriding the medical findings of a Government Medical Board with the personal opinion of the Railway's own Chief Medical Superintendent

2. Whether the rejection order dated 06.02.2025 violated the specific directives issued by the Tribunal in the previous proceedings

The Tribunal applied the principle of administrative fairness and the "rule against bias," holding that state actions must be free from arbitrariness and malice

It relied on the doctrine of judicial discipline, emphasizing that once a competent court passes an order, it is legally binding on the head of the organization

the Tribunal cited the precedent of Israr Ahmad Khan v. Amarnath Prasad & Ors. (2026 INSC 209), which establishes that even if a party believes an order is wrong, they must seek a remedy through the proper judicial hierarchy rather than practicing "willful disobedience," as such conduct borders on criminal contempt and undermines the rule of law

The Tribunal reasoned that the respondents acted arbitrarily by ignoring the conclusive report of the SCB Medical College Board, which was constituted specifically under the Tribunal's prior direction

The Court noted that the CMS, SECR, Bilaspur—who had previously found the applicant unfit—could not offer a "personal opinion" to override a specialized Government Medical Board

The Tribunal found the respondents’ insistence on a 'pachymetry' test to rule out LASIK surgery, after a Board had already cleared the applicant, to be a suspicious and unfair administrative action

By failing to seek clarification from the SCB Medical Board and instead issuing a summary rejection, the respondents violated the spirit of judicial orders and the principles of natural justice

It held that the personal opinion of the CMS cannot supersede a Government Medical Board’s findings

The Tribunal remitted the matter to respondent Nos. 2 and 5 with a directive to seek specific clarifications from the SCB Medical College and Hospital regarding any remaining medical concerns (such as pachymetry). It ordered that the CMS, SECR, Bilaspur must be present during this examination to ensure all technical requirements are met. The respondents were directed to take final action on the applicant's appointment based on the SCB report by August 14, 2026, without seeking further internal medical opinions