Facts
The Petitioner was appointed as a Constable (GD) in the Central Industrial Security Force (CISF) on June 21, 2021
Source reference: p. 2During his basic training at RTC Bhilai, he was diagnosed with Chronic Ulcerative Colitis in July 2021
Source reference: p. 2Following diagnosis, the Petitioner remained away from training for 248 days
Source reference: p. 2-3Over the subsequent years, he was examined by four separate Standing Medical Boards (SMB) and Review Medical Boards between 2023 and 2025
Source reference: p. 3Despite the Respondents extending his probation period four times (six months each) to allow for recovery, the final SMB on October 16, 2025, placed him in a permanent low medical category (S1H1A1P2 E1)
Source reference: p. 3, 7Consequently, the Respondent No. 2 issued the Impugned Order dated January 20, 2026, terminating his services during the probation period
Source reference: p. 1, 3Issues
1. Whether the termination of a probationer on medical grounds without a detailed disciplinary inquiry is arbitrary or violative of the principles of natural justice
Source reference: p. 3, 92. Whether the court can interfere with the medical fitness standards and expert findings determined by the specialized Medical Boards of an armed force
Source reference: p. 5, 8Law Applied
Rule 26(4) of the CISF Rules, 2001, which empowers the appointing authority to terminate the services of a member of the Force during probation without assigning reasons if they fail to pass basic training or are unfit for permanent appointment
Source reference: p. 3, 8The principle that appointment on probation does not confer an indefeasible right to service
Source reference: p. 5Judicial review under Article 226 regarding medical fitness in disciplined forces is limited to cases of mala fides or perversity
Source reference: p. 8-9Reasoning
The Court reasoned that the Petitioner’s medical condition (Ulcerative Colitis) rendered him unable to complete the mandatory basic training required for a Constable
Source reference: p. 6-7It observed that the Respondents demonstrated fairness by extending the Petitioner’s probation four times and conducting multiple medical evaluations rather than terminating him immediately
Source reference: p. 7The Court emphasized that for a disciplined armed force like the CISF, maintaining high physical and medical standards is a "paramount importance"
Source reference: p. 8Since the final medical assessment categorized the Petitioner as "Permanent Low Medical Category," he failed the requirement of "suitability" for the post
Source reference: p. 9The Court held that the termination was a "termination simpliciter" under Rule 26(4), not a punitive action; therefore, a full disciplinary inquiry or a reasoned order was not legally requisite
Source reference: p. 8-9Holding
The Court dismissed the writ petition, holding that there was no infirmity or arbitrariness in the termination order
It concluded that the Petitioner, being a probationer who failed to meet the medical standards for training despite repeated opportunities, had no legal right to continue in service
Source reference: p. 9The temporary or progressive improvement in health does not override the expert opinion of the Standing Medical Board in the context of a disciplined force
Source reference: p. 9All stays or pending applications were vacated
Source reference: p. 10Original Court PDF
Jalu RamvsUnion Of India & Anr.
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