Gauhati High Court

Remand for medical re-examination ordered where Review Medical Board fails to consider conflicting expert civilian medical opinions.

Rajesh Prasad Guwala vs The Union Of India And 7 Ors

Gauhati High CourtJUDGMENT: May 13, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner applied for the post of Constable (GD) and other positions in the Central Armed Police Forces (CAPFs) pursuant to an advertisement dated 05.09.2024

Source reference: p.3

Having successfully cleared the Computer Based Test and Physical Efficiency/Standard Tests, he was subsequently declared medically unfit during the Detailed Medical Examination on three grounds: (i) Penile Vitiligo, (ii) High BP, and (iii) Tachycardia

Source reference: p.3

The petitioner then obtained an independent medical opinion from a civilian doctor at Tezpur Medical College and Hospital on 21.11.2025, who certified him "Fit," stating the vitiligo was stable and did not impede duty

Source reference: p.3

Despite this, the Review Medical Board (RMB) rejected the petitioner solely on the ground of "Penile Vitiligo" without addressing the civilian medical opinion

Source reference: p.3-4
02

Issues

1. Whether the rejection of the petitioner's candidacy by the Review Medical Board solely on the ground of "Penile Vitiligo" was sustainable given the existence of a contradictory medical certificate from a civilian government hospital.

Source reference: p.4
03

Law Applied

The Court exercised its discretionary jurisdiction under Article 226 of the Constitution of India concerning administrative fairness in recruitment processes.

Source reference: p.3-4

The court applied the principle that where contradictory medical opinions exist between specialists and the designated medical board—specifically regarding whether a condition is "stable" or an impediment to duty—the authorities must ensure a comprehensive re-evaluation rather than a perfunctory rejection.

Source reference: p.3-4

The court emphasized the necessity of a reasoned assessment when a candidate presents a "Fit" certificate from a recognized government medical institution

Source reference: p.3-4
04

Reasoning

The Court observed a clear conflict between the findings of the Review Medical Board and the specialized civilian hospital (Tezpur Medical College).

Source reference: p.4

The Court noted that the Review Medical Board's final rejection on the ground of "Penile Vitiligo" lacked a detailed discussion or reference to the civilian doctor's specific finding that the condition was "stable" and "not [causing] any problem in performing his duties"

Source reference: p.4

By failing to account for this expert civilian opinion, the board's decision-making process appeared incomplete. Consequently, the Court determined that the appropriate remedy was not to substitute its own medical judgment, but to remand the matter back to the respondent authorities for a specialized re-examination to resolve the medical ambiguity

Source reference: p.4
05

Holding

The Court disposed of the writ petition by remanding the matter to the respondent authorities. The Court directed the respondents to re-examine the petitioner through a Review Medical Board, involving a specialist if necessary

The Board is ordered to determine if abnormalities truly exist and, if found fit, the authorities must issue consequential appointment orders. A copy of the new medical opinion must be served upon the petitioner. The entire exercise is to be completed within 60 days from the receipt of the certified copy of the order

Source reference: p.4
Gauhati High Court

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Rajesh Prasad GuwalavsThe Union Of India And 7 Ors

Gauhati High Court · May 13, 2026

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