Judicial Review Limited to Expert Medical Board Decisions in Recruitment.

The Respondent, Yashpal Singh, participated in the recruitment process for Constable (Executive) conducted by the Staff Selection Commission (SSC).

He successfully cleared earlier stages and underwent a Detailed Medical Examination (DME) on January 25, 2024.

The Medical Board found him suffering from Varicose Veins in the left leg and declared him medically unfit.

The Respondent then requested and underwent a Review Medical Examination (RME) on January 31, 2024.

The Review Medical Board concurred with the DME's findings, again declaring him medically unfit.

Subsequently, the Respondent produced a medical certificate dated March 30, 2024, from a Government Hospital, stating he was medically fit to participate in competitive or non-competitive examinations.

Relying on this certificate, the Respondent challenged his medical unfitness before the Central Administrative Tribunal (Tribunal).

The Tribunal, on August 20, 2024, allowed the Respondent's Original Application (OA), directing the Petitioners (SSC) to subject him to a fresh medical examination by a newly constituted Medical Board.

The Petitioners have challenged this order before the High Court.

The determination of medical fitness for recruitment to disciplined services falls within the domain of expert Medical Boards.

The scope of judicial review is limited, only extending to situations where the decision-making process is arbitrary, mala fide, or in violation of governing rules.

The Supreme Court's decision in *Indian Council of Agricultural Research & Ors. v. Shashi Gupta* emphasizes judicial restraint when a competent Medical Board's opinion is rendered per prescribed procedure.

The principles established in *Staff Selection Commission & Ors. v. Aman Singh* outline specific, narrowly circumscribed situations warranting interference by courts.

Opinions from private or independently obtained government hospital certificates usually don't form a legitimate basis for re-examination.

The governing framework includes the Advertisement dated September 1, 2023, Standing Order dated June 8, 2022, and the Delhi Police (Appointment and Recruitment) Rules, 1980, particularly Rule 24(2), which concerns medical fitness and conditions interfering with efficient performance of duties.

The court found that the Tribunal's direction for a fresh medical examination was unwarranted given the concurrent findings of both the DME and the RME, which consistently declared the Respondent medically unfit due to Varicose Veins in his left leg.

The court emphasized that the Respondent participated in the recruitment process with full knowledge of the governing medical standards and terms, which were never challenged.

Applying the principles from *Aman Singh (supra)*, the court noted that interference is permissible only in narrowly defined situations such as procedural breaches, demonstrable discrepancies between DME and RME findings, or the absence of a specialist for a condition requiring one.

None of these exceptions were present in this case; instead, there was a concurrence of medical opinion.

The medical certificate dated March 30, 2024, relied upon by the Respondent, was deemed a general fitness certificate, not specific to the Constable (Executive) post, and crucially, was obtained independently by the Respondent, not pursuant to a reference by the Medical Boards.

The court reiterated that opinions from independently obtained medical certificates cannot typically justify a fresh examination, as doing so would undermine the finality of the recruitment process.

The court concluded that it should defer to the expert opinion of the recruiting authorities on whether a specific medical condition renders a candidate unsuitable for a disciplined force, particularly when two expert boards have concurred.

The Impugned Order dated August 20, 2024, passed by the Tribunal in O.A. No.1547/2024 is accordingly set aside, and the Petition filed by the Staff Selection Commission and others is allowed.