Routine SHAPE-I categorisation does not exempt departmental candidates from medical fitness standards prescribed for LDCE selection.

The Petitioner, serving as a Constable/GD in the Central Industrial Security Force (CISF) since 2017, applied for the post of Assistant Sub-Inspector/Executive (ASI/Exe) via the Limited Departmental Competitive Examination (LDCE)-2022.

After qualifying the written and physical tests, he underwent a Detailed Medical Examination (DME) on 28.11.2024, where he was declared "Unfit" due to "Extensive keloid involving chest, back, right arm, right thigh and gluteal region".

A Review Medical Board (RMB) on 29.11.2024 confirmed this finding, noting that the multiple keloids could interfere with wearing combat equipment and cause complications like pain or infections.

The Petitioner challenged these findings, citing his existing SHAPE-I medical category and a private opinion from Dr. Ram Manohar Lohia (RML) Hospital stating he had no physical disability.

1. Whether the Petitioner’s existing SHAPE-I medical status in his current post automatically renders him medically fit for recruitment to a higher post through LDCE

2. Whether the findings of the Review Medical Board regarding the Petitioner’s keloids were arbitrary or contrary to the prescribed medical standards

The court applied Para XII(B)-09 of the "Revised Uniform Guidelines for Review Medical Examination," which mandates that keloid formation is disqualifying if the tendency is marked or interferes with the proper wearing of combatised equipment.

It relied on the Supreme Court precedent in Pavnesh Kumar v. Union of India & Ors. (2023), establishing that SHAPE-I status is merely an eligibility condition for LDCE and does not dispense with the requirement of a fresh, detailed medical examination for the higher post.

the court referred to Staff Selection Commission & Ors. v. Aman Singh, holding that courts should not sit as appellate medical boards over the expert opinions of Force Medical Boards absent evidence of mala fides or perversity.

The court reasoned that LDCE is an "accelerated promotion" and a competitive selection process distinct from normal routine promotion; thus, medical fitness must be assessed against the standards of the higher post at the time of the examination.

Although the Petitioner held a SHAPE-I category for his current duties, the RMB specifically found that his "marked, large and multiple keloids" across five body regions met the disqualification criteria under Para XII(B)-09 because they could impede the use of protective gear and lead to clinical complications like skin carcinoma.

The court dismissed the Petitioner's reliance on the RML Hospital report, noting it only addressed "physical disability" in a general sense and failed to evaluate the Petitioner against the specific "combatised equipment" standards required for a disciplined force.

The court found no procedural irregularity in the RME being conducted one day after the DME, as the 2021 Guidelines permit such a timeline.

The court dismissed the writ petition, holding that the Petitioner failed to demonstrate any perversity or illegality in the Medical Board's decision; clarifying that this judgment only affects fitness for the ASI/Exe post and does not prejudice the Petitioner’s continued service in his current rank.