Disputed Physical Measurement Claims and Prior Certificates Cannot Override Statutory Recruitment Test Results or Warrant Re-evaluation

The petitioner applied for the post of Junior Assistant (Fire Service) with the Airports Authority of India (AAI), Eastern Region. After clearing the Computer Based Test, he participated in the Physical Measurement Test (PMT) on April 18, 2026

To qualify, a candidate requires a normal chest of 81 cm with a 5 cm expansion, with three chances provided

The petitioner was orally informed of his disqualification. He alleged that the authority failed to provide him with the mandated three chances and did not provide documentation of his measurement

He sought a fresh PMT, relying on a 2025 medical report from a Jharkhand Government hospital and a 2015 Jharkhand Staff Selection Commission record indicating he met the physical standards

The respondents contended that a committee of specialist doctors conducted the PMT, three chances were indeed provided to all candidates, and the petitioner failed to raise any immediate grievance on the date of the test

1. Whether the Court can adjudicate upon disputed questions of fact regarding the number of chances provided during a physical measurement test under Article 226 of the Constitution.

2. Whether measurements recorded by external authorities or past examinations can be substituted for the results of a contemporary recruitment process conducted by the designated authority.

3. Whether the petitioner is entitled to a re-evaluation of his physical standards (PMT) through a second chance.

The Court applied the principle that disputed questions of fact cannot be resolved under the writ jurisdiction of Article 226 of the Constitution

Physical standards recorded on the specific date and time of the examination are the only relevant metrics, and measurements from other authorities cannot be relied upon for recruitment (Harun Miah v. Union of India & Ors. FMA 964 of 2025; 2025:CHC-AS:1810-DB)

Public recruitment must adhere to principles of non-discrimination, emphasizing that candidates must be treated uniformly according to the recruitment notice

The Court observed that the petitioner’s claim of being denied three chances was a factual allegation vehemently denied by the respondents, making it an unverifiable "disputed question of fact" unsuitable for writ proceedings

The Court reasoned that the recruitment authority’s measurement on the prescribed date serves as the sole valid assessment; allowing external evidence would undermine the integrity of the recruitment timeline

The Court reasoned that granting the petitioner a second chance for re-evaluation would constitute "discrimination qua the other unsuccessful candidates" and potentially open a floodgate of litigation from other failed aspirants, disrupting the public recruitment process

The writ petition was dismissed, and no relief for a fresh PMT was granted