Candidates participating in a recruitment process cannot challenge its conditions after disqualification; strict adherence to advertised criteria is mandated by constitutional principles of equality.

ORDER :

Parth Prateem Sahu, J.

1. Petitioner has filed this petition seeking following relief (s):-

“10.1 That, Hon’ble Court may kindly be pleased to quash rejection order Annexure P-1 and petitioner may kindly be ordered to be treated as successful and fit for appointed in one of the post for station officer (SI) scheduled tribe.

10.2 That cost of litigation and any other relief which the Hon’ble Court deems fit may kindly also be awarded”

2. Learned counsel for petitioner submits that petitioner being the member of scheduled tribe and having requisite qualification submitted online application form for his appointment to the post of Station Officer (SI) pursuant to the advertisement dated 12.06.2025 (Annexure P-7) by respondent authorities. Thereafter, petitioner was called for physical standard test (PST) and for document verification to be conducted on 17.09.2025 vide Annexure P-1. Petitioner appeared before the respondent authorities for Physical Standard Test on 07.09.2025, where he has been disqualified on the ground that he does not meet the minimum height requirement of 168 cm. He submits that the action on the part of the respondent authorities in disqualifying the candidature of petitioner is bad in law and erroneous. It is contended that, in previous advertisement (Annexure P-6) for the post of Home Guard, minimum height requirement was prescribed at 168 cm and relaxation was given to ST category candidate, however, no such relaxation is given in this in this advertisement for the post of Station Officer (SI) resulting disqualification of the Petitioner. In support of his claim, learned counsel places reliance on Rule 13 of the Chhattisgarh Fire and Emergency Services Rules, 2011 and submits that respondents authorities are duty-bound to adhere to the prevailing reservation rules for SC/ST/OBC and other categories while making appointments or promotions to the subject post.

3. Learned State counsel opposes the submission of learned counsel for petitioner and would submit that advertisement was issued for appointment of various post including the post of Station Officer (SI) in Chhattisgarh Fire and Emergency Services and SDRF, Department inviting applications, from the aspirants having requisite educational qualification meeting physical standards. It is submitted that the advertisement stipulates minimum height of 168 cm for male candidates and a chest measurement of 81 cm (unexpanded) and 86 cm (expanded). However, for candidates belonging to the Scheduled Tribe category, the chest requirements are relaxed to 76 cm (unexpanded) and 81 cm (expanded). He further submits that the physical standard stipulated in the advertisement clearly states that no relaxation shall be granted to any candidate in minimum height. It is further contended that the petitioner is precluded from challenging the terms and conditions of the advertisement as he has participated in this recruitment process. It is argued that time and again, Hon’ble Supreme Court has held that once the aspirant/candidate has appeared in the examination and has participated accepting the conditions of advertisement, he/she thereafter is precluded and restrained from challenging the conditions enumerated in advertisement. He further submits that petitioner was called for the physical standards test and his height was measured through manual and digital machine as 163 cm only, which is below the minimum height of 168 cm as specified in the advertisement. He submits that petitioner was rightly declared disqualified, as he failed to meet the physical standard as stipulated in the advertisement.

4. I have heard learned counsel for parties and perused the documents placed on reco