High Court Remands Case for Re-examination of Disability Status in Recruitment Process — Tribunal's order lacked reasoning on functional capabilities.

High Court: Bombay High Court Bench: BOMBAY
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Case Note & Summary

The Writ Petition No. 2665 of 2025 was filed by a petitioner questioning the validity of an order from the Central Administrative Tribunal that rejected his candidature for the post of Geophysicist in the Geological Survey of India. The petitioner, who holds a Master's degree in Applied Geophysics and is classified as 55% physically handicapped, had successfully cleared all stages of the Combined Geo-Scientist Examination, 2022. However, his candidature was rejected on the grounds of not fulfilling the functional requirements for the post, which specified that candidates must have disabilities classified as one leg affected or one arm affected. The petitioner contended that he was capable of performing the job duties, which included significant desk work, and argued that the Tribunal failed to consider the principle of reasonable accommodation as established by the Supreme Court. The respondents defended the rejection, asserting that the petitioner’s classification of disability did not meet the specified criteria. The court found that the Tribunal's order lacked sufficient reasoning regarding the medical board's findings and emphasized the need for a detailed medical report assessing the petitioner's functional capabilities. The court remanded the matter back to the medical board for a re-evaluation of the petitioner’s fitness for the role, ensuring that the principles of reasonable accommodation were considered. The court also directed that the interim order reserving a post for the petitioner would remain in effect until the medical board's decision was made (Paras 1-54).

Headnote

A) Administrative Law - Recruitment and Disability - Rejection of candidature based on functional requirements - Rights of Persons with Disabilities Act, 2016, Section 2(y) - The Tribunal's order rejecting the petitioner's candidature for Geophysicist was set aside due to lack of specific findings on the functional capabilities of the petitioner despite being declared medically fit. The court emphasized the need for a thorough medical evaluation to ascertain the petitioner's ability to perform job duties in light of his disability (Paras 51-54).

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Issue of Consideration

Whether the rejection of the petitioner's candidature for the post of Geophysicist due to non-fulfillment of functional requirements was justified.

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Final Decision

The court set aside the Tribunal's order and remanded the matter to the Central Standing Medical Board for a re-evaluation of the petitioner's fitness for the role of Geophysicist, emphasizing the need for a detailed medical report on his functional capabilities. The interim order reserving a post for the petitioner was also continued until the medical board's decision was made.

Law Points

  • Writ jurisdiction
  • Reasonable accommodation
  • Medical fitness assessment
  • Functional requirements for employment
  • Rights of Persons with Disabilities Act
  • 2016
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Case Details

2026 LawText (BOM) (11) 6

WP-2665-2025

2026-11-03

Mahesh Chandra Tripathi, Advait M. Sethna

Anjani Kumar Singh, Vritika Bhatia, Shilpa Prashant Gaikwad, Vinod Joshi, Gayatri Khanwilkar, Roma Salunke, Valissa Alphanso, Pranil Sonawane, Vedashree Phadke, Vaishnavi Dalvi

Teklal Kumar Das

Union Public Service Commission, Government of India, Geological Survey of India, Central Standing Medical Board, Union of India

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Nature of Litigation

Writ petition challenging the rejection of candidature for a government post based on disability classification.

Remedy Sought

The petitioner sought to quash the Tribunal's order and be allowed to join the post of Geophysicist.

Filing Reason

The petitioner contested the rejection of his candidature based on non-fulfillment of functional requirements.

Previous Decisions

The Tribunal had previously dismissed the petitioner's application challenging the rejection of his candidature.

Issues

Whether the rejection of the petitioner's candidature was justified based on the functional requirements. Whether the principle of reasonable accommodation was adequately considered.

Submissions/Arguments

The petitioner argued that he was medically fit and capable of performing the job duties despite his disability. The respondents contended that the petitioner's disability classification did not meet the specified functional requirements for the post.

Ratio Decidendi

The court emphasized the necessity of a thorough medical evaluation to determine the functional capabilities of candidates with disabilities in recruitment processes, aligning with the principles of reasonable accommodation under the Rights of Persons with Disabilities Act, 2016.

Judgment Excerpts

The Impugned Order of the Tribunal dated 1st October 2024 is set aside. The Medical Board shall, after examination of the Petitioner, issue a detailed Medical Report on the above basis clearly indicating whether the Petitioner satisfies the functional requirements to work as a Geophysicist.

Procedural History

The petitioner filed a writ petition challenging the Tribunal's order rejecting his candidature, which followed a series of examinations and a medical evaluation that deemed him fit under the PH category.

Acts & Sections

  • Rights of Persons with Disabilities Act, 2016: Section 2(y)
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