Two medical boards’ confirmed knock-knee diagnosis justifies disqualification from police constable appointment.

The respondents issued Advertisement No. 1 of 2023 for appointment to 21,391 posts of Constables in the District Police, Bihar Special Armed Police and other units.

The petitioners applied, were declared successful, and were placed in the final merit list.

During the medical examination conducted on 12 June 2025, the petitioners were declared medically unfit on account of “knock knee”.

On their representations, a second Medical Board constituted at PMCH examined them on 8 August 2025 and confirmed the diagnosis, following which the petitioners were not appointed.

The petitioners relied on medical reports obtained from AIIMS, Patna and IGIMS, Patna, which allegedly did not find knock knee, and sought quashing of the disqualification communications, recognition as medically fit, or a fresh medical examination.

1. Whether the petitioners could be disqualified from appointment as Constables on the ground of “knock knee” when, according to them, the condition was not expressly prescribed as an eligibility requirement in Advertisement No. 1 of 2023 or Rule 663 of the Bihar Police Manual, 1978.

2. Whether the medical opinions of AIIMS, Patna and IGIMS, Patna, allegedly finding no knock knee, justified interference with the findings of the recruitment Medical Boards.

3. Whether the petitioners were entitled to a further medical examination and a writ directing their appointment in accordance with the final merit list.

The Court applied the principle that physical fitness is of primary importance for appointment to police forces and that the medical standards applicable to police and armed forces personnel are more stringent than those applicable to civilian employment.

Relying on K.M. Priyanka v. Union of India, W.P. (C) No. 10783 of 2020, and the decisions cited therein, including Priti Yadav v. Union of India, Jonu Tiwari v. Union of India, Nishant Kumar v. Union of India and Sharvan Kumar Rai v. Union of India, the Court held that, in the absence of mala fides, the opinion of the specialised Medical Boards constituted for recruitment to the Forces ordinarily prevails over contrary opinions of private or other government doctors, who may not assess fitness by reference to the operational demands of service.

The Court also relied on the principle that, where a candidate has already availed the available appeal or review medical process, a further examination is generally unwarranted.

Rule 663 of the Bihar Police Manual, 1978 was raised by the petitioners, but the judgment did not independently interpret or decide its applicability.

The Court treated the petitioners’ physical fitness as an essential consideration for police appointment because the post involves physically demanding duties.

The petitioners had not merely been rejected on the basis of one medical opinion: the initial Medical Board found knock knee on 12 June 2025, and a subsequently constituted PMCH Medical Board independently confirmed the diagnosis on 8 August 2025.

Applying K.M. Priyanka, the Court held that the contrary reports from AIIMS and IGIMS could not displace the findings of the recruitment Medical Boards in the absence of any allegation or proof of mala fides, particularly when the recruitment Boards assess candidates against the specific physical requirements of police service.

Since the petitioners had already received a second medical assessment, the Court found no justification for directing another examination or ordering appointment.

It upheld the findings of the two Medical Boards that the petitioners suffered from knock knee and were medically unfit for appointment as Constables.

The Court found no merit in either writ petition and dismissed both applications, declining to quash the disqualification communications, order a further medical examination, or direct appointment.