CAT - ['Delhi']

Recruitment Rules barring LASIK surgery in disciplined forces are valid policy decisions immune from judicial interference.

Bharat Yadav vs DEPARTMENT OF PERSONNEL AND TRAINING

CAT - ['Delhi']JUDGMENT: April 30, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants were candidates for the post of Constable (Executive) in the Delhi Police who successfully cleared the competitive examination and physical tests.

Source reference: no citation

they were declared medically unfit during the Detailed Medical Examination (DME) and subsequent Review Medical Boards because they had undergone refractive/LASIK surgery to improve visual acuity

Source reference: p. 52, 57

The applicants challenged the validity of the Notification dated 22.10.2018, which amended the medical standards to specifically disqualify candidates who had undergone surgery of any kind to improve vision, arguing it was arbitrary and ignored medical advancements

Source reference: p. 51-54

The respondents contended that medical standards are a matter of policy, and the applicants, having participated in the recruitment process with full knowledge of the disqualification criteria, were estopped from challenging them

Source reference: p. 58-60
02

Issues

1. Whether the amendment/notification dated 22.10.2018, incorporating disqualification for LASIK surgery, is arbitrary, unconstitutional, and violative of Articles 14 and 16

Source reference: p. 51 & 72

2. Whether candidates can challenge recruitment rules and medical standards after participating in the selection process without protest

Source reference: p. 58 & 80

3. Whether the medical standards of the Delhi Police can be equated with those of other forces like the Railway Protection Force (RPF)

Source reference: p. 77
03

Law Applied

Section 147(1) and (2) of the Delhi Police Act, 1978, which empowers the Administrator to prescribe recruitment and service conditions

Source reference: p. 63

principle of Estoppel, as established in Om Prakash Shukla v. Akhilesh Kumar Shukla, which prevents candidates from challenging selection criteria after participating and failing

Source reference: p. 81

executive discretion in classification is valid if guided by a definite objective (Jyoti Pershad v. Administrator for the Union Territory of Delhi)

Source reference: p. 69-72

distinction between "Police" and other services as per the State of Punjab v. Barkat Ram doctrine regarding the broad functional mandate of a disciplined force

Source reference: p. 80
04

Reasoning

The Tribunal observed that the 2018 amendment was introduced following a transparent consultative process where a Public Notice was issued, yet no objections were raised by the applicants at that time

Source reference: p. 82-83

The court reasoned that the employer has the prerogative to set medical standards based on functional requirements; specifically, the Delhi Police consulted experts from AIIMS who warned that LASIK patients might struggle with night glare and requires annual check-ups, which is incompatible with the "extreme weather" and "night duty" requirements of the executive cadre

Source reference: p. 75

The Tribunal distinguished the applicants' reliance on the Supreme Court's Dalbir v. UOI (RPF case), noting that RPF duties are "non-technical" and less taxing than the Delhi Police, which operates under a comprehensive mandate for maintaining public order and safety

Source reference: p. 77-78

Consequently, the classification was found to have a rational nexus with the objective of maintaining a robust, disciplined force

Source reference: p. 73
05

Holding

The Tribunal answered the issues in the negative and dismissed the batch of Original Applications

the 2018 amendment is not arbitrary but a valid exercise of policy-making power intended to ensure the physical fitness of a disciplined force

Source reference: p. 73, 83

the applicants were barred by the principle of acquiescence from challenging the rules after voluntarily participating in the recruitment process

Source reference: p. 81

The orders of medical unfitness were upheld, and no relief was granted

Source reference: p. 84
CAT - ['Delhi']

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Bharat YadavvsDEPARTMENT OF PERSONNEL AND TRAINING

CAT - ['Delhi'] · April 30, 2026

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