Medical Opinion of Recruitment Boards Prevails Over External Private Certificates in Disciplined Force Appointments

The Petitioner applied for the post of Constable/GD in the Central Reserve Police Force (CRPF) through the 2018 recruitment process.

She was declared medically fit during a Detailed Medical Examination (DME) in January 2020 and received a provisional offer of appointment in February 2021.

Upon reporting to the Group Centre in Bengaluru on March 15, 2021, she underwent a fresh medical examination as her previous DME was over a year old.

This fresh examination on March 22, 2021, declared her unfit due to tachycardia and coarse tremors.

A Review Medical Board (RMB) subsequently confirmed her unfitness due to a "hyperthyroid state" involving Graves’ disease.

Consequently, her offer of appointment was cancelled on June 29, 2021.

The Petitioner challenged this cancellation, relying on a later medical certificate from a civilian institute stating she could perform duties with regular checkups.

1. Whether the cancellation of the Petitioner’s offer of appointment, based on a fresh medical examination and the findings of the Review Medical Board, was arbitrary or legally unsustainable.

2. Whether a candidate who was fit at the initial recruitment stage has a vested right to appointment if found unfit at the time of reporting for duty.

The court applied the principle that recruitment to disciplined forces (Armed Forces, Paramilitary, or Police) requires higher standards of fitness compared to civilian roles.

It followed the precedent set in Staff Selection Commission Ors. v. Aman Singh, 2024:DHC:8441-DB, which establishes that while judicial review of Medical Boards is permissible, the court cannot act as an appellate medical authority unless there is proof of mala fides, procedural breach, or patent arbitrariness.

the court upheld the CRPF Directorate General instructions (dated 07.04.2014) requiring a fresh medical examination if the gap between the initial DME and appointment exceeds one year.

The Court reasoned that the CRPF was justified in conducting a second medical exam because more than one year had elapsed since the Petitioner's first examination in January 2020.

The RMB's findings were based on objective medical evidence, including an ultrasonography (USG) showing bulky thyroid lobes and blood tests showing high Anti-TPO antibodies and persistent tachycardia (heart rate of 142 bpm).

The court noted that the Petitioner’s reliance on a civilian medical certificate actually reinforced the RMB’s diagnosis, as it confirmed she had Graves' disease and required radioactive iodine therapy.

The court emphasized that it would not substitute its own opinion for that of specialized medical experts, especially since no mala fides or procedural irregularities were alleged against the RMB.

The Petitioner's stay at the center for 107 days did not create a vested right to appointment, as the offer was explicitly conditional upon passing the fresh medical exam.

It held that in the absence of perversity, mala fides, or breach of procedure, the assessment made by the medical authorities of the Force must prevail over outside medical opinions.

The court concluded that the medical standards of the CRPF are framed based on the rigorous demands of the service, and the Petitioner did not meet those standards at the time of entry into service.