Delhi High Court

Independent medical reports cannot override expert recruitment board findings absent established procedural or legal infirmity.

Govt Of Nct Delhi & Anr. vs Krishna Nand Singh Yadav

Delhi High CourtJUDGMENT: March 20, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Respondent applied for the post of Constable (Executive) in the Delhi Police Examination, 2023

Source reference: para. 4

During the recruitment process, he was declared medically unfit by a Detailed Medical Examination (DME) in January 2024 due to "Right dome of diaphragm mild raised with blunt CP angle"

Source reference: para. 6

A subsequent Review Medical Examination (RME) conducted on January 27, 2024, confirmed the disqualification based on the same underlying condition

Source reference: para. 6

Relying on an independent medical opinion obtained outside the recruitment process, the Respondent challenged the findings before the Central Administrative Tribunal (CAT)

Source reference: para. 7

On August 27, 2024, the CAT directed a fresh medical examination at a different government hospital, citing parity with its previous orders in similar cases

Source reference: para. 9

The Petitioners (Govt. of NCT Delhi) challenged this order before the High Court, arguing that the Respondent had already been examined twice by competent boards and no provision for further re-examination exists

Source reference: para. 8
02

Issues

Whether the Tribunal was justified in directing a fresh medical examination of the candidate despite concurrent findings of unfitness by the DME and RME, and without identifying specific procedural or legal infirmities in those examinations

Source reference: para. 10
03

Law Applied

The Court primarily applied the principles established in Staff Selection Commission v. Aman Singh (2024 SCC OnLine Del 7600), which mandates judicial circumspection in recruitment to disciplined forces, stating that courts cannot sit in appeal over expert medical opinions unless there is a breach of procedure, a material discrepancy between DME and RME, or a lack of specialist evaluation

Source reference: para. 11

It further relied on SSC v. Amit Goswami (2024 SCC OnLine Del 7985), which holds that independent medical reports obtained by candidates cannot displace the findings of duly constituted Medical Boards

Source reference: para. 12

The Court also referenced SSC v. Ravina Meena (2024:DHC:9147-DB) to emphasize that judicial intervention must be case-specific rather than based on general parity

Source reference: para. 13
04

Reasoning

The Court found that the CAT’s order lacked a legal basis because it failed to identify any procedural irregularity, bias, or lack of expertise in the DME and RME

Source reference: para. 16

Although the DME and RME used slightly different phraseology, the Court determined that the substance of the disqualifying condition remained concurrent and undisturbed

Source reference: para. 14-15

Applying Aman Singh, the Court reasoned that the fitness standards for disciplined forces are strict and deference must be shown to the recruiting agency’s expert boards

Source reference: para. 11, 18

The Court criticized the Tribunal for granting relief solely on the basis of "parity of disposal" with other cases rather than a factual scrutiny of the Respondent's specific circumstances

Source reference: para. 17, 20

Consequently, the Respondent’s independent medical report was insufficient to warrant a third medical board when the official recruitment boards had consistently affirmed his unfitness

Source reference: para. 19-20
05

Holding

The High Court answered the issue in the negative, holding that the Tribunal was not justified in directing a fresh medical examination without evidence of exceptional circumstances or procedural defects

The Court allowed the Writ Petition and set aside the CAT’s order dated August 27, 2024, in O.A. No. 2386/2024

Source reference: para. 22

The pending application was also closed

Source reference: para. 23
Delhi High Court

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Govt Of Nct Delhi & Anr.vsKrishna Nand Singh Yadav

Delhi High Court · March 20, 2026

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