Facts
The Petitioner, a Constable/GD in the Central Industrial Security Force (CISF) since 2010, applied for the post of Head Constable/Ministerial through the Limited Departmental Competitive Examination (LDCE) notified on 21.01.2019
Source reference: p. 2Although he qualified in the written and physical tests, the Detailed Medical Board (DMEB) declared him "UNFIT" on 08.12.2023 due to "Defective Color Vision"
Source reference: p. 2Upon appeal, a Review Medical Board (RMEB) confirmed this finding, categorizing his vision as CP-IV (Four) on 19.01.2024
Source reference: p. 2The Petitioner challenged these findings, producing opinions from two government hospital specialists (Hindu Rao and ABVIMS RML Hospital) who categorized his vision as CP-III (Three)
Source reference: p. 2The Respondents maintained that the Petitioner failed to meet the mandatory CP-III standard required by the MHA Guidelines dated 20.05.2015
Source reference: p. 3Issues
1. Whether the Court can exercise its writ jurisdiction to quash the findings of a specialized Review Medical Board and direct the constitution of an independent Medical Board based on external medical opinions
Source reference: p. 1-2, 9-10Law Applied
The court applied the principles governing judicial review of medical fitness in disciplined forces, primarily relying on the precedent set in Staff Selection Commission Ors. v. Aman Singh (2024 SCC OnLine Del 7600).
Source reference: p. 3-4This doctrine establishes that judges are not medical experts and must defer to specialized Medical Boards unless there is a proven breach of procedure, notable discrepancy between DMEB and RMEB findings, lack of specialists on the board, or evidence of mala fides.
Source reference: p. 4-8The court underscored that standards for paramilitary forces are higher than civilian roles, and external medical opinions do not inherently justify a re-examination if the official boards were qualified and followed protocol.
Source reference: p. 7-8Reasoning
The Court reasoned that the scope of judicial review is restricted to examining the process rather than substituting its own opinion for that of experts.
Source reference: p. 3It noted that the Petitioner did not deny having a medical condition but merely disputed the degree of impairment (CP-IV vs CP-III).
Source reference: p. 9The Court observed that both the DMEB and RMEB, consisting of domain specialists, arrived at a concurrent finding of CP-IV.
Source reference: p. 9Following the Aman Singh guidelines, the Court held that since the official boards were sufficiently equipped and qualified, the outside medical opinions obtained by the Petitioner—even if from government hospitals—could not override the specialized assessment of the Forces' own medical boards.
Source reference: p. 9-10No mala fides or procedural irregularities were demonstrated to warrant extraordinary intervention.
Source reference: p. 9Holding
The Court dismissed the writ petition, holding that it would not interfere with the expert findings of the Medical Boards.
It concluded that the Petitioner failed to meet the requisite recruitment standards for vision, and in the absence of exceptional circumstances or procedural breach, the court cannot direct the re-constitution of a third Medical Board. All pending applications were also dismissed.
Source reference: p. 10Original Court PDF
Sagun Kumar ChandanvsUnion Of India & Anr.
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