Medical unfitness cannot rest solely on deformity without assessing functional fitness for the post.

The applicant applied for appointment as a Constable (Driver) in the Delhi Police.

He was declared medically unfit on account of amputation through the distal phalanx of the left middle finger.

He underwent an initial medical examination on 28 January 2014, a Review Medical Examination on 16 January 2015, and a further medical examination on 19 September 2017 pursuant to directions issued by the Tribunal in the earlier round of litigation.

In the earlier proceedings, the Tribunal directed that the appellate medical examination be conducted afresh and that the candidates’ cases be considered with reference to the functional requirements of the post.

The subsequent Medical Board recorded that the applicant had an amputated distal phalanx of the left middle finger and, relying on the applicable guidelines concerning loss or deformity of a finger, declared him unfit.

The applicant contended that the Medical Board had not examined whether the finger deformity actually affected his ability to perform the duties of Constable (Driver), despite the earlier directions of the Tribunal.

The respondents relied on Rule 24 and Appendix XXX of the Delhi Police (Appointment & Recruitment) Rules, 1980, particularly the provisions permitting rejection for defects likely to render a candidate unfit for police duties and specifically referring to loss or deformity of fingers.

Whether the applicant’s medical unfitness could be sustained solely on the existence of amputation or deformity of the left middle finger, without assessing its impact on the functional requirements of the post of Constable (Driver).

Whether the respondents had complied with the earlier direction of the Tribunal requiring a fresh medical assessment with reference to the functional requirements of the post.

Whether the applicant was entitled to a further functional medical assessment and consequential appointment if found otherwise eligible.

The Tribunal applied Rule 24(2) and (3) of the Delhi Police (Appointment & Recruitment) Rules, 1980, under which medical examination must assess whether a disease or defect is likely to render a candidate unfit for police service, and the appointing authority may reject candidates whose physical standards are inadequate.

It also considered Para (K) of Appendix XXX, which authorises rejection for a disease or defect likely to render a recruit unfit for the duties of the particular branch, while identifying loss or deformity of fingers as a condition that should not be overlooked.

The Tribunal further applied the principle that medical unfitness must be assessed in relation to the candidate’s actual capacity to perform the duties of the post, as reflected in the Tribunal’s earlier order in the applicant’s case, and in Staff Selection Commission & Anr. v. Mohit Kumar, W.P.(C.) No. 2268/2025, where the Delhi High Court required consideration of whether a finger deformity impeded the candidate’s functioning as a Delhi Police constable.

The Tribunal also referred to Kavinder Singh v. SSC & Ors., O.A. No. 4307/2017, concerning the impermissibility of relying on speculative or unsupported assumptions rather than an assessment connected to actual job performance.

Although Rule 24 and Appendix XXX permitted consideration of finger deformity as a possible ground of unfitness, the relevant test was whether the defect was likely to impair the applicant’s ability to discharge the duties of the particular post.

The Medical Board merely recorded the amputation and invoked the guideline concerning loss or deformity of fingers; it did not give a specific opinion on whether the condition affected the applicant’s functional ability to perform the duties of a Constable (Driver).

This failed to comply with the earlier Tribunal direction requiring assessment with reference to the functional requirements of the post.

Following the reasoning in Mohit Kumar, the Tribunal held that the existence of a physical deformity and its actual impact on job performance were distinct questions.

The applicant therefore required a medical assessment specifically addressing whether the left middle-finger condition impeded his efficient discharge of the duties attached to the post.

The exercise was to be completed within two months from receipt of the order.

If the applicant was found functionally fit and otherwise eligible, the respondents were directed to take consequential action and issue him an offer of appointment in accordance with the applicable rules.

The O.A. and all pending miscellaneous applications were disposed of, with no order as to costs.