Anand Oraon v. The Union Of India And ORS

IN THE HIGH COURT AT CALCUTTA

CIRCUIT BENCH AT JALPAIGURI 24.03.2026 Sl. No.10 tkm W. P. A. 2574 of 2025 [Anand Oraon-Vs- Union of India& Ors.] Mr. Bikramaditya Ghosh Ms. Ved Rai Mr. M Bhandari Mr. Vivek Saha ... ... for the petitioner Mr. Sudipto Kr. Mazumder, ld DSGI Mr. Sudip Kr. Paul ... for the respondents 1.

The affidavit of service is taken on record.

2.

The petitioner has preferred the present writ petition challenging (i) the medical report dated 19.11.2025 issued pursuant to the Detailed Medical Examination, (ii) the medical report dated 20.11.2025 issued pursuant to the Review Medical Examination, and (iii) the communication dated 10.12.2025, whereby the petitioner's candidature for the post of Constable (GD) in the Central Armed Police Forces (CAPFs) has been rejected.

3.

Learned counsel for the petitioner submits that the petitioner had applied for the post of constable (GD) in the Central Armed Police Forces pursuant to a notification issued by the Staff Selection Commission.

4.

It is submitted that petitioner successfully cleared the computer based examination and thereafter also qualified in the physical standard test/physical efficiency test. The petitioner was subsequently called for Document Verification Detailed Medical Examination (DV/DME).

It is submitted that upon such medical examination, the petitioner was declared medically unfit on the ground of severe 'skin infection in the perineum and genital area'.

Being aggrieved thereby, petitioner availed of the opportunity of Review Medical Examination wherein he was again declared unfit on the ground of extensive 'tinea cruris'. It is further submitted that the petitioner was referred to the MJM hospital for specialist's opinion where the dermatologist opined that the condition of 'tinea cruris' is a fungal infection which is curable noncommunicable.

5.

It is further submitted that the petitioner subsequently obtained medical reports from both the government and private hospitals which indicate that the petitioner is presently not suffering from any such skin disease. It is contended that the petitioner had submitted

a representation dated 29.11.2025. However, respondent authorities by a communication dated 10.12.2025 rejected the same on the ground that there is no provision for appeal against the decision of the Review Medical Board and that the petitioner had already been declared unfit by the medical board consisting of three medical officers. Being aggrieved by the said decision, the petitioner has preferred the present writ petition.

6.

Learned counsel for the petitioner further submits that the impugned action of the respondent is arbitrary and violative of Article 14 and 16 of the Constitution of India. It is further contended that the condition of 'tinea cruris'

is a minor curable noncommunicable in nature and does not render the petitioner permanently unfit for service. It is argued that the rejection of the petitioner's candidature on the basis of a temporary and curable condition is unreasonable disproportionate.

7.

Per contra, Mr. Mazumder, learned DSGI submits that the petitioner was subjected to detailed medical examination and thereafter review medical examination by duly

constituted medical board comprising expert doctors as per the applicable recruitment rules governing CAPFs.

In both examinations, petitioner was found medically unfit. It is submitted that under the applicable recruitment rules governing the CAPFs, the decision of the review medical board is final and binding and no provision for any further appeal is provided under the recruitment rules.

8.

It is further submitted by the learned DSGI that the judicial review in such matter is extremely limited and this court ought not to interfere with the opinion of the expert Medical Board which has already conducted two medical examinations of the petitioner.

9.

This court has heard arguments advanced by the parties and perused the materials on record. The question which falls for consideration is whether the decision of the respondent authority in declaring the petitioner medically unfit suffers from arbitrariness, illegality or procedural informity so as to warrant interference under Article 226 of the Constitution. It is well settled that the matters related to medical fitness for recruitment process such as that

of the Central Armed Police Forces, the opinion of the duly constituted medical board is entitled to considerable weight. The scope of judicial review in such cases is limited.

This court does not act as an appellate authority over the findings of the expert medical bodies and would interfere only when the decision making process is shown to be vitiated by mala fides, arbitrariness or patent irregularities apparent on the face of record. In the present case, the petitioner was declared medically unfit in the detailed medical examination on the ground of severe skin infection. Thereafter upon availing of the opportunity of Review Medical Examination, he was again declared unfit on the ground of 'tinea cruris'. Thus two independent medical examinations conducted by the expert bodies consistently found the petitioner to be medically unfit.

The contention of petitioner that such condition is curable and non-communicable even if accepted, cannot by itself rendered the decision of the medical board arbitrary, biased or actuated by mala fide intention. The standard of medical fitness for recruitment to the CAPFs are necessarily stringent having regard to the nature of the

duties to be discharged. It is within the domain of the expert medical authorities to assess the overall fitness of a candidate including the possibility of re-occurrence and the impact of such condition on service requirements.

The subsequent medical certificates produced by the petitioner from private other hospitals indicating absence of the disease cannot override the finding of the duly constituted medical boards conducted as part of the recruitment process. It is settled position that such certificates obtained de hors the prescribed procedure cannot be a ground to displace the opinion of a statutorily constituted Medical Board. This court finds no illegality in the process followed by respondent in conducting the medical examination. The representation of the petitioner was duly considered by the respondent authorities.

However, in view of the finality attached to the decision of the Review Medical Board under the applicable rules, the respondents declared declined to interfere with the findings of the medical board. Such decision cannot be said to be arbitrary or unreasonable.

10. In view of aforesaid facts circumstances of the case, this court is of the considered view that no case for interference has been made out by the petitioner to exercise the writ jurisdiction. The impugned decision is based on the opinion of the expert medical board rendered in accordance with the prescribed procedure and does not suffer from any infirmity warranting interference under Article 226 of the Constitution.

11. Accordingly the present petition is dismissed. However, the petitioner is at liberty to participate in the future recruitment process if otherwise eligible in accordance with law. (Gaurang Kanth, J.)