CAT - ['Guwahati']
Employment and Labour LawAdministrative and Public Law

Courts cannot substitute their view for competent medical-board findings on fitness.

SRI JAYANTA ACHARJEE vs N.F.RAILWAY

CAT - ['Guwahati']JUDGMENT: September 11, 20263 MIN READSOURCE JUDGMENT
Courts cannot substitute their view for competent medical-board findings on fitness.. SRI JAYANTA ACHARJEE vs N.F.RAILWAY. CAT - ['Guwahati']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a Track Maintainer-II in the N.F. Railway, developed serious back-related medical problems and was found medically unfit for the heavy physical duties of his post by the Divisional Medical Committee on 28 October 2020, although he continued to remain in medical category A-3.

Source reference: para. 3

As no suitable light-duty post was available in his parent cadre, he was placed under the Personnel Department and was initially offered alternative employment as Tech-II/Carpenter.

Source reference: para. 3

Pursuant to his request for a category change, he was offered and joined the post of Junior Clerk in the Personnel Department by order dated 16 September 2024.

Source reference: para. 3

In February 2025, the respondents directed the applicant to undergo a re-medical examination.

Source reference: para. 4

The Divisional Medical Committee examined him on 17 March 2025 and concluded that no further light-duty recommendation was necessary, while finding him medically fit in category A-3.

Source reference: para. 4

Relying on that opinion, the respondents issued Order No. E/283/LMG/EQ/2025/Pt.I dated 21 April 2025, relieving him from the post of Junior Clerk and directing him to report to his parent cadre as Track Maintainer-II.

Source reference: paras. 1, 4

The applicant challenged the re-medical examination and the repatriation order, seeking retention as Junior Clerk and the associated benefits.

Source reference: para. 2
02

Issues

Whether the respondents’ direction requiring the applicant to undergo a re-medical examination was illegal or contrary to the applicable railway rules?

Source reference: paras. 2, 3, 6

Whether the applicant, having been offered the post of Junior Clerk as alternative employment after medical de-categorisation, was entitled to continue in that post?

Source reference: paras. 2, 3

Whether the order dated 21 April 2025 directing the applicant to return to his parent cadre as Track Maintainer-II was liable to be quashed?

Source reference: paras. 1, 4, 7
03

Law Applied

The Tribunal considered Rule 561(A)(2) and Rule 561(A)(4) of the Indian Railway Medical Manual, which concern the provision of light duty and the placement of an employee on the sick list where suitable light duty is unavailable.

Source reference: para. 3

It also relied upon Rules 1301–1304 of the Indian Railway Establishment Manual, governing medical de-categorisation and the provision of alternative employment to Railway servants who become physically incapable of performing their original duties.

Source reference: para. 3

The Tribunal further applied the applicable medical re-examination schedule, under which employees in medical categories A-1 to A-3 are ordinarily re-examined every four years if below 45 years and every two years if above 45 but below 55 years.

Source reference: para. 6

The governing principle applied was that a court or tribunal should not ordinarily substitute its own assessment for the opinion of a duly constituted medical expert committee in the absence of grounds warranting interference.

Source reference: para. 7
04

Reasoning

The Tribunal accepted the respondents’ reliance on the prescribed re-examination schedule and held that the applicant’s re-medical examination was conducted pursuant to the applicable medical-service provisions.

Source reference: para. 6

The subsequent Medical Board did not recommend any further light-duty arrangement and found that the applicant’s medical status had not changed; he remained fit in category A-3.

Source reference: paras. 4, 6

Since the competent medical authority had found him fit for the duties of his original cadre, the Tribunal declined to reassess or substitute its view for that of the medical experts.

Source reference: para. 7

Consequently, the Tribunal found no legal basis to interfere with the respondents’ decision to relieve the applicant from the Personnel Department and direct him to resume duties as a Track Maintainer-II.

Source reference: paras. 7–8
05

Holding

The Tribunal answered the issues against the applicant.

It upheld the validity of the re-medical examination and the order dated 21 April 2025 directing his return to the parent Track Maintainer cadre, finding no merit in the challenge to the respondents’ action.

Source reference: paras. 7–8

The Original Application was dismissed, the interim order dated 20 May 2025 was vacated, pending miscellaneous applications were disposed of, and there was no order as to costs.

Source reference: paras. 8–9
CAT - ['Guwahati']

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SRI JAYANTA ACHARJEEvsN.F.RAILWAY

CAT - ['Guwahati'] · September 11, 2026

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