Failure to meet mandatory physical standards justifies cancellation of appointment without prior show-cause notice.

The appellant was recruited as a Constable (GD) in the Special Armed Forces on October 21, 2013, after a District Medical Board recorded his height as 168 cm

Following a complaint, a Divisional Medical Board re-examined the appellant and recorded his height as 167.5 cm

Upon the appellant's request, a final examination by the State Medical Board recorded his height as 167 cm

Consequently, his appointment was cancelled on April 23, 2019, as he fell short of the prescribed 168 cm requirement

The appellant challenged this cancellation via a writ petition, which was dismissed on February 17, 2026

The present matter is an intra-court appeal against that dismissal

1. Whether the cancellation of the appellant’s appointment was valid given that his height was found to be below the mandatory requirement of 168 cm prescribed under the recruitment rules

2. Whether the termination of services without a prior show-cause notice constituted a violation of the principles of natural justice

3. Whether the court can exercise leniency or direct the adjustment of the appellant in an alternative service due to the marginal nature of the height deficiency

The court primarily applied Rule 22(1)(i) of the M.P. Special Armed Forces Rules, 1973, which mandates a minimum height of 5'6" (168 cm) for direct recruitment into the Special Armed Forces

The court also relied on the administrative law principle that the rules of natural justice are not a "straight-jacket formula" and a hearing is not required where it would amount to an "empty formality"

The court reasoned that Rule 22(1)(i) establishes a mandatory eligibility criterion that the appellant failed to meet, as evidenced by the findings of the State Medical Board which recorded his height at 167 cm

Regarding the lack of a show-cause notice, the court determined that since the appellant’s failure to meet the statutory height requirement was a verified physical fact, providing a hearing would have served no purpose; thus, the "empty formality" doctrine applied

Furthermore, the court rejected the plea for leniency, emphasizing that the Special Armed Forces perform high-stakes duties involving the prevention of dangerous offences and the apprehension of hazardous individuals, which necessitates strict adherence to physical qualifications

The court concluded that the Single Judge’s findings were based on an accurate application of the law to the facts on record

The court held that the cancellation of the appellant's appointment was legal and justified because he did not satisfy the mandatory eligibility criteria under the 1973 Rules

The court further held that no indulgence or leniency could be granted for unqualified personnel in the Special Armed Forces