Case Note & Summary
The petitioner, Prem Ravindra Kumbhre, applied for the post of Sub-Inspector in Delhi Police and Central Armed Police Forces (CAPFs) in response to an advertisement published by the Staff Selection Commission on 04.03.2024. He successfully cleared the Tier-I examination on 21.10.2024 and the Tier-II examination on 08.03.2025. Following this, he was directed to undergo a medical examination, which was conducted by the Medical Board of Composite Hospital, CRPF, GC Pune on 20.09.2025. The Medical Board declared him medically unfit on four grounds: Ankyloglossia, Bilateral Cubitus Valgus CA-22 degree, Haemorrhoids, and Abnormal or unseen upper gluteal region with whitening of skin between it. Aggrieved by this report, the petitioner requested a Review Medical Examination. On 22.09.2025, the Medical Review Board examined him and opined that he was medically unfit due to an abnormal opening at the glutted cleft present with fatty tissue bulge on the right side. The petitioner then filed a writ petition under Article 226 of the Constitution challenging the Medical Unfit Certificate dated 22.09.2025 as arbitrary, illegal, and in violation of the Revised Uniform Guidelines for Review Medical Examination in Central Armed Police Forces and Assam Rifles. He sought quashing of the certificate and a direction to consider him medically fit. The respondents argued that the Medical Review Board's decision is final and not open to further appeal, and that the petitioner had already availed the remedy of review. They cited a Supreme Court order in SLP No.738-741/2022 dated 20.10.2023, which held that the decision of the Review Medical Board should be treated as final. The court considered the rival submissions and perused the medical certificates. It noted that the Medical Review Board had indeed declared the petitioner unfit and that there is no provision for a second review. The court held that it is not an expert body and cannot substitute its own opinion for that of the medical board. Finding no violation of applicable guidelines, the court dismissed the writ petition with no order as to costs.
Headnote
A) Service Law - Recruitment - Medical Fitness Standards - Central Armed Police Forces (CAPFs) and Delhi Police - Finality of Medical Review Board's Decision - Revised Uniform Guidelines For Review Medical Examination In Central Armed Police Forces and Assam Rifles; Order dated 20.10.2023 in SLP No.738-741/2022 - Petitioner was declared medically unfit initially and upon review for abnormal opening at glutted cleft with fatty tissue bulge. He challenged the review board's certificate as illegal and contrary to guidelines. The Court, relying on the Supreme Court's direction that review board decisions are final, dismissed the petition, noting that the court is not an expert to review medical findings and no violation of guidelines was shown. Held that no interference is warranted. (Paras 2-9).
Issue of Consideration
Whether the Medical Unfit Certificate issued by the Medical Review Board is illegal, arbitrary, and violative of principles of natural justice, warranting interference under writ jurisdiction.
Final Decision
Writ petition dismissed. Court held that Medical Review Board's decision is final per Supreme Court order in SLP No.738-741/2022, court not expert to review medical findings, no guideline violation. No costs.
Law Points
- Decision of Medical Review Board is final
- Court cannot substitute its own opinion for that of medical experts
- Revised Uniform Guidelines for Review Medical Examination in CAPFs and Assam Rifles to be followed
- Medical unfitness certificate not interfered with unless arbitrary or violative of guidelines
