01Facts
The Appellants (SBI) advertised for Probationary Officers in 2021, reserving posts for persons with disabilities, including locomotor disabilities.
¶ 2The Respondent, a candidate with a benchmark locomotor disability, was provisionally selected.
¶ 3-4During the mandatory medical examination, reports from Apollo Hospital revealed the Respondent had a failed kidney transplant and was on dialysis thrice weekly due to chronic kidney disease.
¶ 6Consequently, the Bank’s Medical Officer declared him unfit for appointment.
¶ 8The Respondent challenged this in a writ petition; the learned Single Judge quashed the Bank’s decision, holding that chronic kidney disease was not a specific disqualification and directed his appointment.
¶ 11-13The Bank appealed this decision via a Letters Patent Appeal.
¶ 1402Issues
i.1. Whether a candidate with a benchmark locomotor disability, applied for under the reserved category, can be rendered ineligible for selection on the grounds of a medical ailment (renal failure) under the Bank’s general fitness standards.
¶ 25ii.2. Whether the "Standard of Fitness for New Recruits" prescribed for general candidates is applicable to persons with disabilities recruited under the specific quota.
¶ 29, 4403Law Applied
Interpretation of the State Bank of India Officers’ Service Rules, 1992, specifically Rule 14 regarding appointment guidelines.
¶ 26The Bank’s E-Circular dated 12.04.2012, containing "Standards of Medical Fitness for New Recruits/Promotees," specifically Part A, Part C(ii), and Part C(x).
¶ 27, 32, 42Legislative intent of the Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995 (and the 2016 Act).
¶ 30, 37The Supreme Court’s observations in State Bank of India v. Ranjit Kumar Rajak regarding institutional sensitivity.
¶ 5004Reasoning
The Court determined that Part A of the Bank’s fitness norms, which requires candidates to be "free from any physical defect," inherently excludes persons with disabilities, as they possess physical defects by definition.
¶ 29The Court reasoned that Part C(ii), which disqualifies general recruits for kidney failure, was intended to detect "hidden" ailments in otherwise healthy candidates.
¶ 36The Court highlighted Part C(x), a specific provision for physically handicapped candidates, which states that for promotion within identified posts, standard fitness norms for general candidates are "not applicable".
¶ 42-44Drawing an analogy for recruitment, the Court held that once a post is identified for a specific disability, the Bank cannot defeat the purpose of the 1995/2016 Act by applying general medical disqualifications (like renal failure) to non-suit a disabled candidate.
¶ 38-39The Court further noted that the Respondent had already demonstrated functionality by clearing the selection process, and modern medical progress ensures that conditions like dialysis do not render a person entirely "non-functional".
¶ 5905Holding
The Court held that the general standards of fitness regarding systemic diseases like renal failure do not apply to candidates selected under the disability quota, as these candidates fall under the specialized category in Clause C(x), where general standards are expressly excluded.
¶ 45, 48The Court dismissed the Bank’s appeal and upheld the Single Judge’s order directing the Bank to issue an appointment order to the Respondent as a Probationary Officer within eight weeks.
¶ 60, 61, 62Original Court PDF
STATE BANK OF INDIAvsNAVEEN VENKATA YELURI
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