1. Recruitment for Management Trainee — Candidate with multiple disabilities declared unfit — Dispute over benchmark disability and eligibility under Rights of Persons with Disabilities Act, 2016. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 )
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2026 Supreme(SC) 52
SUPREME COURT OF INDIA
J.B.PARDIWALA, K.V. VISWANATHAN, JJ.
Sujata Bora – Appellant
Versus
Coal India Limited & Ors. – Respondents
Civil Appeal No. 120 of 2026
Decided On : 13-01-2026
Advocates appeared:
For the Petitioner(s): Mr. Amol Nirmalkumar Suryawanshi, Adv. Mr. Prashant Shrikant Kenjale, Adv. Mr. B Dhananjay, Adv. Ms. Damini Vishwakarma, Adv. M/s Juristrust Law Offices, AOR
For the Respondent(s): Mr. Vivek Narayan Sharma, AOR Mrs. Mahima Bhardwaj Kalucha, Adv. Mr. Akash Singh, Adv. Mr. Adhiraj Wadhera, Adv. Mr. Dinesh Sharma, Adv. Mr. Rajeev Kumar Jha, Adv. Mr. Shubham Awasthi, Adv.
For the Petitioner(s): Mr. Amol Nirmalkumar Suryawanshi, Adv. Mr. Prashant Shrikant Kenjale, Adv. Mr. B Dhananjay, Adv. Ms. Damini Vishwakarma, Adv. M/s Juristrust Law Offices, AOR
For the Respondent(s): Mr. Vivek Narayan Sharma, AOR Mrs. Mahima Bhardwaj Kalucha, Adv. Mr. Akash Singh, Adv. Mr. Adhiraj Wadhera, Adv. Mr. Dinesh Sharma, Adv. Mr. Rajeev Kumar Jha, Adv. Mr. Shubham Awasthi, Adv.
Reasonable accommodation is a fundamental right ensuring equality for persons with disabilities; technicalities should not obstruct justice for discrimination cases.
Headnote:(A) Rights of Persons with Disabilities Act, 2016 - Importance of reasonable accommodation highlighted - Appellant selected for Management Trainee role but was declared unfit due to disability - High Court ruled CIL must modify recruitment notifications to consider applicants with multiple disabilities - Division Bench overturned this, citing panel expiry - Supreme Court reinstated Single Judge's decision to allow participation in recruitment process, noting that reasonable accommodation is a fundamental right and serves to ensure full societal participation for individuals with disabilities. (Paras 13-36)
(B) Reasonable Accommodation - Defined as necessary modifications to ensure individuals with disabilities enjoy rights equally with others - Failure to provide such accommodation constitutes discrimination. (Paras 12, 13)
(C) Intersectionality of disability and gender recognized; technicalities like panel expiry should not bar justice in cases of discrimination against women with disabilities. (Paras 22-23)
Legal Category Hierarchy
- constitutional law
- administrative law
- social welfare law
-
corporate law
- corporate social responsibility
- environmental social and governance
Table of Contents
2. Whether the expiry of the recruitment panel bars the court from granting relief to a candidate wrongly denied employment due to disability assessment. (Para 3 )
3. Reasonable accommodation is a fundamental gateway right ensuring substantive equality; disability rights should be viewed through the prism of intersectionality and corporate social responsibility. (Para 13 , 14 , 15 , 16 , 17 )
4. Reasonable accommodation is a facet of substantive equality under Articles 14 and 21, necessitating flexibility to ensure persons with disabilities enjoy rights equally with others. (Para 13 , 15 , 17 )
5. What is the concept of reasonable accommodation under the RPwD Act, 2016?
It refers to necessary and appropriate modifications and adjustments, without imposing a disproportionate or undue burden, to ensure persons with disabilities enjoy or exercise rights equally with others. It is a fundamental gateway right and a facet of substantive equality. (Para 13 , 15 )
JUDGMENT
J. B. PARDIWALA & K. V. VISWANATHAN, J.J.
Lack of physical sight does not equate to a lack of vision.
- Stevie Wonder
1. An advertisement was published by Coal India Limited (CIL) for recruitment of Management Trainees in 2019. The appellant applied for the post under the Visually Handicapped (VH) category. appellant was selected for the interview. By a communication of 1st July 2021 appellant was called for document verification (DV) and Initial Medical Examination (IME). The appellant appeared for the IME in September 2021, however, she was declared unfit on the ground that she was not only suffering from visual disability but also from residuary partial hemiparesis. Aggrieved the appellant filed WPA No. 970 of 2023 before the High Court of Judicature at Calcutta.
2. A learned Single Judge (Lapita Banerjee J.) after a thorough analysis of the relevant provisions of the Rights of Persons with Disabilities Act, 2016, (for short ‘RPwD Act’) and the relevant notifications found that CIL being a Public Sector Corporation could not refuse appointment in the multiple disabilities category and that it was incumbent upon CIL to suitably modify the recruitment notifications. The learned Single Judge found that the IME result of 23.09.2021 that declared the appellant unfit, was liable to be quashed. However, since, the appellant approached the Court after the completion of the recruitment process. The Court allowed the appellant to participate in the ensuing recruitment process (2023) in the reserved category for persons with disability. The learned Single Judge made it clear that the recruitment process of the appellant will be considered from the stage of IME, and if found eligible she will be given appointment as Management Trainee upon compliance of all formalities. The learned Single Judge’s judgment was dated 10.08.2023. It must also be pointed out that pending the disposal of the writ petition, by an interim order dated 27.03.2023, one post was ordered to be kept vacant in the cadre of management trainee (personnel and HR).
3. CIL carried the matter to the Division Bench. The Division Bench, by the impugned, order found that the writ petition was filed after the expiry of the panel and even the interim order was passed after the expiry of panel and hence, directing the authorities to consider the candidature in respect of the same recruitment process or in the next recruitment process was not tenable. The Division Bench set aside the judgment of the Single Judge.
4. Aggrieved, the appellant carried the matter to this Court. This Court, by multiple orders on 28.11.2025, 12.12.2025 and 18.12.2025, directed the All India Institute of Medical Sciences to constitute a Board of experts and for coopting Dr. Satendra Singh who has been working on disability rights for a long time.
5. The order dated 18.12.2025 which incorporates all the earlier orders reads as under.
“1. Our order dated 28-11-2025 reads thus:-
1. It is the case of the petitioner that she is a visually handicapped person with 60% low vision in both eyes and also has residual functional partial Hemiparesis.
2. In terms of qualification, the petitioner has graduated with the degree in Economics and pursued post graduation from Assam Women's University in MBA (Human Resources).
3. The respondent no.1 is a Maharatna Public Sector Undertaking under the Ministry of Coal, Government of India.
4. It appears from the materials on record that in pursuance of the advertisement dated 16.12.2019 issued by the respondent no.1- company, the petitioner applied for the post of a Management Trainee in Personnel and HR discipline.
5. She applied as a reserved candidate in the Visually Handicapped (VH) category.
6. It is her case that she produced two certificates dated 7.4.2012 and 2.1.2021 respectively, issued by the District Social Welfare Officer, Jorhat, Government of Assam and the Public Works Department, Government of Assam through the Joint Director of Health Sciences, Jorhat, respectivel
