Skip to content
Order
  • Library
  • Features
  • About
  • Blog
  • Contact
Get started
Book a Demo

Order

At Order.law, we’re building India’s leading AI-powered legal research platform.Designed for solo lawyers, law firms, and corporate legal teams, Order helps you find relevant case law, analyze judgments, and draft with confidence faster and smarter.

Product

  • Features
  • Blog

Company

  • About
  • Contact

Legal

  • Privacy
  • Terms

Library

  • Acts
  • Judgments
© 2026 Order. All rights reserved.
  1. Home/
  2. Library/
  3. High Court Of Delhi/
  4. 2024/
  5. November

Staff Selection Commissioner & Ors. vs. Neelam Rani & Anr.

Decided on 30 November 2024• Citation: W.P.(C)/14749/2024• High Court of Delhi
Download PDF

Read Judgment


              $~6                                                                 
              *    IN THE  HIGH  COURT   OF  DELHI  AT NEW   DELHI                
                                           Date of decision: 30.11.2024           
              +    W.P.(C) 14749/2024 & CM APPL. 61948/2024                       
                   STAFF SELECTION  COMMISSIONER   & ORS.                         
                                                          .....Petitioners        
                                  Through: Mr.Farman  Ali, SPC   with             
                                           Ms.Laavanya  Kaushik, GP,              
                                           Ms.Usha  Jamnal, Mr.Krishan            
                                           Kumar, Advs.                           
                                  versus                                          
                   NEELAM  RANI & ANR.               .....Respondents             
                                  Through: Ms.Esha  Mazumdar, Mr.Setu             
                                           Niket,  Ms.Unni  Maya  S.,             
                                           Mr.Devansh Khatter, Advs. for          
                                           R-1                                    
                                           Mr.Kanav Vir Singh, SPC for            
                                           R-2.                                   
                   CORAM:                                                         
                   HON'BLE  MR. JUSTICE  NAVIN  CHAWLA                            
                   HON'BLE  MS. JUSTICE SHALINDER   KAUR                          
              NAVIN CHAWLA,   J. (Oral)                                           
              1.   This petition has been filed by the petitioners challenging the
              Order dated 22.03.2024 passed by the learned Central Administrative 
              Tribunal, Principal Bench, New Delhi (hereinafter referred to as,   
              ‘Tribunal’) in Original Application (in short, ‘OA’) No.441/2024    
              titled Neelam Rani v. Staff Selection Commission & Ors., whereby    
              the said petition filed by the respondent no.1 herein was allowed and
              the petitioners herein were directed to constitute a fresh medical  
              board, which must include a specialist, within a period of six weeks
              from the date of receipt of the certified copy of the said Impugned 
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 1 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

              Order, for examining the respondent no.1 herein. It was also directed
              that in the event the respondent no.1 herein is declared medically fit,
              then, subject to meeting other criteria, the respondent no.1 herein shall
              be appointed to the post of Constable (Executive) Female in the Delhi
              Police.                                                             
              2.   The facts giving rise to the present petition may be summarised
              as under:                                                           
                a. The petitioners advertised 7547 posts of Constable (Executive) 
                   Male   and  Female   in   the  Delhi  Police  vide             
                   notification/advertisement dated 01.09.2023. The respondent    
                   no.1 applied for the said post and underwent the Computer      
                   Based Examination (CBE) and the Physical Endurance and         
                   Measurement Test (PE&MT). Thereafter, the respondent no.1      
                   was subjected to an examination by a Detailed Medical          
                   Examination (in short, “DME”) Board, which vide report dated   
                   22.01.2024 declared the respondent no.1 unfit for appointment  
                   to the post of Constable (Executive), by observing as under:   
                b. Thereafter, the respondent no.1 applied for an examination by  
                   the Review Medical Examination (in short, ‘RME’) Board,        
                   which was conducted on 28.01.2024. The RMB again declared      
                   the respondent no.1 unfit for appointment on the ground of     
                   “B/L renal calculi” and “hematuria”.                           
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 2 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

                c. The respondent no.1 claims to have got herself examined at the 
                   Maharishi Valmiki Hospital, where no malfunction in the        
                   kidney was found. The respondent no.1 then got herself         
                   examined at Dr. Mishra's X-Ray & Ultrasound Clinic, where it   
                   was reported that “Both kidneys are normal in shape, size,     
                   outline and position. No hydronephrosis or calculus is seen on 
                   either side.”                                                  
                d. Armed with these reports, the respondent no.1 approached the   
                   learned Tribunal seeking the relief of appointment to the post of
                   Constable (Executive) Female in the Delhi Police.              
                e. The said petition, as noted hereinabove, has been allowed by the
                   learned Tribunal directing the petitioners herein to constitute a
                   fresh medical board for examining the respondent no.1.         
              3.   The learned counsel for the petitioners submits that in the    
              present case, the Review Medical Board had based its opinion on the 
              Clinical Study Reports of the respondent no.1, which clearly shows  
              the presence of stones in the kidneys and also the presence of blood in
              her urine. She submits that these reports could not have been brushed
              aside by the learned Tribunal based on some subsequent reports      
              produced by the respondent no.1.                                    
              4.   On the other hand, the learned counsel for the respondent no.1 
              submits that there is an inconsistency between the report of the DME
              Board and the RME Board; the DME Board only reported presence of    
              red blood cells in the urine of the respondent no.1 and not hematuria,
              which was the basis on which the RME Board declared the respondent  
              no.1 unfit for appointment. Further, there was no report of presence of
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 3 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

              kidney stones in the DME, and this was a new finding given by the   
              RME Board.                                                          
              5.   We have considered the submissions made by the learned         
              counsels of the parties.                                            
              6.   This Court in Staff Selection Commission & Ors. v. Aman        
              Singh 2024:DHC:8441-DB, on  a detailed examination of the           
              precedents on the subject, has stated the following principles as   
              applicable to a challenge to a medical examination of a candidate for
              appointment in the Delhi Police:                                    
                             “10.38 In our considered opinion, the                
                             following principles would apply:                    
                             (i) The principles that apply in the case of         
                             recruitment to disciplined Forces, involved          
                             with safety and security, internal and external,     
                             such as the Armed and Paramilitary Forces,           
                             or the Police, are distinct and different from       
                             those which apply to normal civilian                 
                             recruitment. The standards of fitness, and the       
                             rigour of the examination to be conducted, are       
                             undoubtedly higher and stricter.                     
                             (ii) There is no absolute proscription against       
                             judicial review of, or of judicial interference      
                             with, decisions of Medical Boards or Review          
                             Medical Boards. In appropriate cases, the            
                             Court can interfere.                                 
                             (iii) The general principle is, however,             
                             undoubtedly one of circumspection. The Court         
                             is to remain mindful of the fact that it is not      
                             peopled either with persons having intricate         
                             medical knowledge, or were aware of the              
                             needs of the Force to which the concerned            
                             candidate seeks entry. There is an irrebuttable      
                             presumption that judges are not medical men          
                             or persons conversant with the intricacies of        
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 4 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

                             medicine, therapeutics or medical conditions.        
                             They must, therefore, defer to the decisions of      
                             the authorities in that regard, specifically of      
                             the Medical Boards which may have assessed           
                             the candidate. The function of the Court can         
                             only, therefore, be to examine whether the           
                             manner in which the candidate was assessed           
                             by the Medical Boards, and the conclusion            
                             which the Medical Boards have arrived,               
                             inspires confidence, or transgresses any             
                             established norm of law, procedure or fair           
                             play. If it does not, the Court cannot itself        
                             examine the material on record to come to a          
                             conclusion as to whether the candidate does,         
                             or does not, suffer from the concerned ailment,      
                             as that would amount to sitting in appeal over       
                             the decision of the Medical Boards, which is         
                             not permissible in law.                              
                             (iv) The situations in which a Court can             
                             legitimately interfere with the final outcome of     
                             the examination of the candidate by the              
                             Medical Board or the Review Medical Board            
                             are limited, but well-defined. Some of these         
                             may be enumerated as under:                          
                                  (a) A breach of the prescribed                  
                                  procedure that is required to be                
                                  followed during examination constitutes         
                                  a legitimate ground for interference. If        
                                  the examination of the candidate has not        
                                  taken place in the manner in which the          
                                  applicable Guidelines or prescribed             
                                  procedure requires it to be undertaken,         
                                  the examination, and its results,               
                                  would ipso facto stand vitiated.                
                                  (b) If there is a notable discrepancy           
                                  between the findings of the DME and             
                                  the RME, or the Appellate Medical               
                                  Board, interference may be justified. In        
                                  this, the Court has to be conscious of          
                                  what constitutes a “discrepancy”. A             
                                  situation in which, for example, the            
                                  DME finds the candidate to be suffering         
                                  from three medical conditions, whereas          
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 5 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

                                  the RME, or the Appellate Medical               
                                  Board, finds the candidate to be                
                                  suffering only from one of the said three       
                                  conditions, would not constitute a              
                                  discrepancy, so long as the candidate is        
                                  disqualified because of the presence of         
                                  the condition concurrently found by the         
                                  DME and the RME or the Appellate                
                                  Medical Board. This is because, insofar         
                                  as the existence of the said condition is       
                                  concerned, there is concurrence and             
                                  uniformity of opinion between the DME           
                                  and the RME, or the Appellate Medical           
                                  Board. In such a circumstance, the              
                                  Court would ordinarily accept that the          
                                  candidate suffered from the said                
                                  condition. Thereafter, as the issue of          
                                  whether the said condition is sufficient        
                                  to justify exclusion of the candidate from      
                                  the Force is not an aspect which would          
                                  concern the Court, the candidate's              
                                  petition would have to be rejected.             
                                  (c) If the condition is one which requires      
                                  a specialist opinion, and there is no           
                                  specialist on the Boards which have             
                                  examined the candidate, a case for              
                                  interference is made out. In this,              
                                  however, the Court must be satisfied            
                                  that the condition is one which requires        
                                  examination by a specialist. One may            
                                  differentiate, for example, the existence       
                                  of a haemorrhoid or a skin lesion which         
                                  is apparent to any doctor who sees the          
                                  candidate, with an internal orthopaedic         
                                  deformity, which may  require                   
                                  radiographic examination and analysis,          
                                  or an ophthalmological impairment.              
                                  Where the existence of a medical                
                                  condition which ordinarily would                
                                  require a specialist for assessment is          
                                  certified only by Medical Boards which          
                                  do not include any such specialist, the         
                                  Court would be justified in directing a         
                                  fresh examination of the candidate by a         
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 6 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

                                  specialist, or a Board which includes a         
                                  specialist. This would be all the more so       
                                  if the candidate has himself contacted a        
                                  specialist who has opined in his favour.        
                                  (d) Where the Medical Board, be it the          
                                  DME or the RME or the Appellate                 
                                  Medical Board, itself refers the                
                                  candidate to a specialist or to another         
                                  hospital or doctor for opinion, even if         
                                  the said opinion is not binding, the            
                                  Medical Board is to provide reasons for         
                                  disregarding the opinion and holding            
                                  contrary to it. If, therefore, on the aspect    
                                  of whether the candidate does, or does          
                                  not, suffer from a particular ailment, the      
                                  respondents themselves refer the                
                                  candidate to another doctor or hospital,        
                                  and the opinion of the said doctor or           
                                  hospital is in the candidate's favour,          
                                  then, if the Medical Board, without             
                                  providing any reasons for not accepting         
                                  the verdict of the said doctor or               
                                  hospital, nonetheless disqualifies the          
                                  candidate, a case for interference is           
                                  made out.                                       
                                  (e) Similarly, if the Medical Board             
                                  requisitions specialist investigations          
                                  such   as   radiographic or                     
                                  ultrasonological tests, the results of the      
                                  said tests cannot be ignored by the             
                                  Medical Board. If it does so, a case for        
                                  interference is made out.                       
                                  (f) If there are applicable Guidelines,         
                                  Rules or Regulations governing the              
                                  manner in which Medical Examination             
                                  of the candidate is required to be              
                                  conducted, then, if the DME or the RME          
                                  breaches the stipulated protocol, a clear       
                                  case for interference is made out.              
                             (v) Opinions of private, or even government,         
                             hospitals, obtained by the concerned                 
                             candidate, cannot constitute a legitimate basis      
                             for referring the case for re-examination. At        
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 7 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

                             the same time, if the condition is such as           
                             require a specialist's view, and the Medical         
                             Board and Review Medical Board do not                
                             include such specialists, then the Court may be      
                             justified in directing the candidate to be re-       
                             examined by a specialist or by a Medical             
                             Board which includes a specialist. In passing        
                             such a direction, the Court may legitimately         
                             place reliance on the opinion of such a              
                             specialist, even if privately obtained by the        
                             candidate. It is reiterated, however, that, if the   
                             Medical Board or the Review Medical Board            
                             consists of doctors who are sufficiently             
                             equipped and qualified to pronounce on the           
                             candidate's condition, then an outside medical       
                             opinion obtained by the candidate of his own         
                             volition, even if favourable to him and              
                             contrary to the findings of the DME or the           
                             RME, would not justify referring the candidate       
                             for a fresh medical examination.                     
                             (vi) The aspect of “curability” assumes              
                             significance in many cases. Certain medical          
                             conditions may be curable. The Court has to          
                             be cautious in dealing with such cases. If the       
                             condition is itself specified, in the applicable     
                             Rules or Guidelines, as one which, by its very       
                             existence, renders the candidate unfit, the          
                             Court may discredit the aspect of curability. If     
                             there is no such stipulation, and the condition      
                             is curable with treatment, then, depending on        
                             the facts of the case, the Court may opine that      
                             the Review Medical Board ought to have given         
                             the candidate a chance to have his condition         
                             treated and cured. That cannot, however, be          
                             undertaken by the Court of its own volition, as      
                             a Court cannot hazard a medical opinion              
                             regarding curability, or the advisability of         
                             allowing the candidate a chance to cure the          
                             ailment. Such a decision can be taken only if        
                             there is authoritative medical opinion, from a       
                             source to which the respondents themselves           
                             have sought opinion or referred the candidate,       
                             that the condition is curable with treatment. In     
                             such a case, if there is no binding time frame       
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 8 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

                             within which the Review Medical Board is to          
                             pronounce its decision on the candidate's            
                             fitness, the Court may, in a given case, direct a    
                             fresh examination of the candidate after she,        
                             or he, has been afforded an opportunity to           
                             remedy her, or his, condition. It has to be          
                             remembered that the provision for a Review           
                             Medical Board is not envisaged as a chance           
                             for unfit candidates to make themselves fit, but     
                             only to verify the correctness of the decision of    
                             the initial Medical Board which assessed the         
                             candidate.                                           
                             (vii) The extent of judicial review has, at all      
                             times, to be restricted to the medical               
                             examination of the candidate concerned. The          
                             Court is completely proscribed even from             
                             observing, much less opining, that the medical       
                             disability from which the candidate may be           
                             suffering is not such as would interfere with        
                             the discharge, by her, or him, of her, or his,       
                             duties as a member of the concerned Force.           
                             The suitability of the candidates to function as     
                             a member of the Force, given the medical             
                             condition from which the candidate suffers,          
                             has to be entirely left to the members of the        
                             Force to assess the candidate, as they alone         
                             are aware of the nature of the work that the         
                             candidate, if appointed, would have to               
                             undertake, and the capacity of the candidates        
                             to undertake the said work. In other words,          
                             once the Court finds that the decision that the      
                             candidate concerned suffers from a particular        
                             ailment does not merit judicial interference,        
                             the matter must rest there. The Court cannot         
                             proceed one step further and examine whether         
                             the ailment is such as would render the              
                             candidate unfit for appointment as a member          
                             of the concerned Force.”                             
              7.   In the present case, though the DME Board does not expressly   
              say that the respondent no.1 is suffering from hematuria, at the same
              time, as per the medical literature, presence of red blood cells in the
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 9 of 10                 
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52                                                                      

              urine is itself called hematuria. In any case, the RME Board has based
              its opinion on the clinical examination report of the ultrasound and CT
              of the respondent no.1. These reports have also been produced before
              us in the present petition.                                         
              8.   As held by this Court in Aman Singh (supra), once the Medical  
              Boards have followed the procedure in detail and there is no infirmity
              found in the same, being based on the clinical examination reports, the
              power of judicial review available with the Court is rather restricted.
              The Court cannot substitute its own opinion based on some medical   
              reports produced by a candidate at a later stage.                   
              9.   Accordingly, we are of the opinion that the learned Tribunal has
              erred in allowing the OA filed by the respondent no.1 and issuing   
              directions to the petitioners to have the respondent no.1 re-examined
              by a fresh medical board. This would lead to an unending exercise of
              recruitment which cannot be permitted in the absence of very cogent 
              material that may lead to a serious doubt being raised on the reports of
              the DME Board or the RME Board. In our view, the respondent no.1    
              had not met this threshold for interference of the Court.           
              10.  Accordingly, we allow the present petition and set aside the   
              Impugned Order dated 22.03.2024 passed by the learned Tribunal.     
              The pending application also stands disposed of.                    
                                                   NAVIN  CHAWLA,  J              
                                                 SHALINDER   KAUR, J              
              NOVEMBER    30, 2024/rv/SJ                                          
                                      Click here to check corrigendum, if any     
    Signature Not Verified                                                        
              W.P.(C) 14749/2024                     Page 10 of 10                
    Digitally Signed                                                              
    By:SUNIL                                                                      
    Signing Date:10.12.2024                                                       
    14:53:52