Notification-Prescribed Medical Standards Prevail Over Principles Applicable to Serving Employees and Non-PWD General Candidates.

The applicant applied for the post of Senior Clerk cum Ticket Examiner (Level-5) under the Southern Railway (Notification dated 28.02.2019).

Following document verification, a medical examination found the applicant unfit for the "Bee Two" (B-2) medical classification due to a hearing impairment in the right ear; he was certified fit only for "Cee One" (C-1).

His candidacy was rejected via order dated 31.05.2023.

The applicant filed an Original Application (OA), arguing that the post was suitable for Persons with Disabilities (PWD) and that precedent required only a "Cee Two" (C-2) classification.

The Tribunal dismissed the OA on 02.07.2025.

The applicant subsequently filed this Review Application, alleging an error apparent on the face of the record regarding the misapplication of the S.K.M. Haider precedent.

1. Whether there is an error apparent on the face of the record in the Tribunal's previous order to justify a review.

2. Whether the medical classification "Bee Two" prescribed in the recruitment notification can be bypassed by a general category candidate based on standards applicable to PWD candidates.

3. Whether the ratio in S.K.M. Haider v. Union of India regarding medical standards for ticket examiners applies to direct recruitment after the 2019 merger of categories.

The Tribunal applied the principles governing Review Jurisdiction, which require an "error apparent on the face of the record" rather than a mere disagreement with the judgment.

It distinguished the precedent in S.K.M. Haider v. Union of India (2011), noting it addressed medical classifications for serving employees (promotion) prior to the 2019 merger of the Senior Commercial Clerk and Ticket Examiner categories.

The Tribunal further applied the principle that PWD standards (under the PWD Act) constitute a separate "benchmark" that general category candidates cannot claim to satisfy minimum physical requirements.

The Tribunal reasoned that the applicant could not claim benefits intended for PWD candidates because he had explicitly declared himself a non-PWD candidate in his application; thus, he was bound by the general category's medical standards.

Regarding the S.K.M. Haider case, the Tribunal found no error in its previous dismissal, clarifying that the 2019 notification (Annexure A-2) governed the recruitment.

Since the Senior Commercial Clerk and Ticket Examiner categories were merged in 2019, the new common "Bee Two" medical requirement held the field for direct recruits.

The Tribunal concluded that the applicant was attempting to re-argue the merits of the case, which is impermissible in a review application.

The Review Application was dismissed, and no costs were awarded.

The court affirmed that recruitment must strictly follow the medical standards prescribed in the specific employment notification.