Findings of a Railway Medical Board prevail over external medical certificates for determining recruitment fitness.

The applicant applied for Level-1 posts under Central Employment Notice (CEN) No. RRC 01/2019

After clearing the written examination with a percentile of 98.22538 and passing the Physical Efficiency Test (PET), he underwent a medical examination at Bilaspur on February 22, 2023

He was declared medically 'unfit' for categories A-2, A-3, and B-1 due to defective color vision but 'fit' for B-2 and below

The applicant challenged this by submitting medical certificates from a private hospital, AIIMS Raipur, and a District Hospital, all of which certified his color vision as normal

Upon appeal, a specialized Medical Board (including an Ophthalmologist) was constituted at Nagpur on June 30, 2023, which reaffirmed the initial finding of refractive error and defective color vision

The applicant sought a fresh medical board involving AIIMS doctors, alleging that the Railway's findings were arbitrary and that the merger of posts (Assistant Depot Store) prejudiced his appointment

The respondents contended that the applicant did not meet the merit cutoff for the B-2/C-1 categories he was found fit for

1. Whether the medical findings of the Railway Medical Board can be set aside based on contrary medical reports from non-railway government institutions like AIIMS

2. Whether the applicant is entitled to a third medical examination by a fresh medical board

3. Whether the re-adjustment or merger of vacancies by the Railway Administration was arbitrary or violative of Article 14

Para 3.0 of the Recruitment Notification, which mandates that candidates must fulfill prescribed medical standards for opted posts, failing which no alternative appointment is granted

Para 506 of the Indian Railway Medical Manual-1 (IRMM-1), which stipulates that there is no inherent right of appeal against a medical board's decision, though a second board may be granted if an error of judgment is evidenced

Anupal Singh v. State of Uttar Pradesh (2020) 2 SCC 173, establishing that administrative correction of vacancy calculations does not constitute a change in the rules of selection

The principle from MPPSC v. Manish Bakawala (Civil Appeal No. 7721/2021), holding that candidates who participate in a selection process without demur cannot later challenge the rules or administrative adjustments to the detriment of others

The Tribunal observed that the applicant was afforded the opportunity of a re-examination by an independent Medical Board at Nagpur, which included a subject specialist (Ophthalmologist), following his appeal against the initial Bilaspur report

Both railway medical reports consistently found the applicant unfit for high-vision categories (A-2 to B-1)

Under Para 506 of the IRMM-1, such external certificates are merely "evidence" to justify the constitution of a second board, rather than absolute proof of fitness that supersedes the Railway Board’s specialized findings

The Tribunal distinguished the present case from Ajay v. Union of India (OA 450/2024), noting that here, the two examinations were conducted by different sets of doctors at different locations, ensuring impartiality

Regarding the merger of posts, the Tribunal found that the respondents exercised their administrative right to re-adjust vacancies per Para 1.10 of the CEN

Since the applicant’s score (65.66) was significantly lower than the last empanelled UR candidate in the B-2/C-1 category (77.88), no relief could be granted

The Tribunal concluded that the OA was devoid of merit as the applicant failed to meet the medical standards for his opted posts and lacked the merit score for the categories he was found fit for

The Original Application was dismissed without costs