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2026 Supreme(Gau) 813

THE GAUHATI HIGH COURT, (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH)
SOUMITRA SAIKIA, J.
Rajesh Prasad Guwala, S/o. Ramdular Guwala – Petitioner 
Versus 
The Union of India, Represented By The Secretary To The Union Of India, Ministry Of Home Affairs and Ors. – Respondent 
WP(C)/7294 of 2025
Decided On : 13-05-2026

Advocates Appeared:
For the Petitioner: Mr M. Ahmed, A.K. Kanu
For the Respondents: DY.S.G.I., Mr. S.S. Roy (C.G.C.).

Where a candidate faces rejection due to medical unfitness, the failure of the reviewing board to analyze or reconcile a contradictory medical report from an external specialist renders the decision arbitrary, necessitating a fair re-examination by a medical specialist.

Headnote:(A) Recruitment - Medical fitness - Conflict in medical opinions - Where a candidate is declared unfit for service despite an independent specialist certificate attesting to their fitness, the reviewing authority is obligated to address the variance in findings. (Paras 2-3)

(B) Administrative decision-making - Duty of fairness - Failure to discuss or refer to a competing medical opinion before arriving at a final rejection renders the decision deficient. Proper assessment requires reconciliation of contradictory medical evidence. (Paras 3-4)

Facts of the case:
The petitioner, having successfully cleared the physical and written stages of a recruitment process, was found medically unfit. A subsequent expert evaluation obtained by the petitioner declared them fit, noting the condition was stable and would not impede their duties. The final medical review board upheld the rejection based solely on the original findings without addressing the contradictory evidence.

Findings of Court:
The court observed that the omission to review or consider the external expert opinion, which directly contested the basis of rejection, invalidated the finding of the medical board.

Issues: Whether the rejection of a candidate by a medical board without reconciling competing medical opinions regarding fitness for service constitutes a valid administrative decision.

Ratio Decidendi: Authorities conducting medical examinations for recruitment must ensure transparency and fairness, specifically by addressing and reconciling conflicting medical reports from qualified specialists before finalizing a decision on physical suitability.

Result: Petition disposed of. Respondent directed to re-examine the petitioner through a specialist and pass a reasoned order based on the findings.

Table of Content
1. contradictory medical evaluation reports during recruitment fitness assessment. (Para 1 , 2 , 3)
2. judicial mandate for medical re-examination to resolve clinical uncertainty. (Para 4)
3. procedural disposal of writ petition with time-bound administrative directions. (Para 5)

JUDGMENT :

SOUMITRA SAIKIA, J.

Heard Mr. M. Ahmed, learned counsel for the petitioner. Also heard Mr. S.S Roy, learned CGC for the respondents.

2. The petitioner, in response to the advertisement dated 05.09.2024 issued by the Staff Selection Commission, applied for the recruitment to the post of Constable (GD) in the Central Armed Police Forces (CAPFs), SSF, and Rifleman (GD) in Assam Rifles and Sepoy in Narcotics Control Bureau Examination for the year-2025. The petitioner claims to assert eligibility for the post, thus participating in the recruitment process. The petitioner was declared successful in both the Computer Based Test as well as the Physical Standard Test (PST)/ Physical Efficiency Test (PET). However, during the subsequent Medical Examinations, i.e. Detailed Medical Examination, he was found unfit on the following grounds:

(i) Penile Vitiligo; (ii) High BP and (iii) Tachycardia.

3. Subsequently, he was examined by a Civilian Doctor in the Tezpur Medical College and Hospital and by the opinion dated 21.11.2025, he is found to be fit and the Doctor of the Tezpur Medical College and Hospital had opined that the “patient is having penile vitiligo since childhood. The condition is stable. It is not cause any problem in performing his duties. Patient is fit to performing his normal activities and duties”. Thereafter, he was placed before the Review Medical Board where he was finally rejected on the ground of “Penile Vitiligo”. There was no discussion or reference to the opinion of the civilian hospital where there is a detailed opinion granted that the petitioner is fit for being appointed to his duties.

4. Under such circumstances, in view of the contradictory medical opinions, this Court considers it appropriate to remand the matter back to the respondent authorities to re-examine the petitioner by referring to specialist if the need so arises thereafter pass appropriate order. The examination will be conducted by the review medical board and thereafter if it is found that there are no abnormalities present then consequential orders should be issued. Any such opinion rendered in terms of the directions, copies thereof will be served on the writ petitioner.

5. The writ petition stands accordingly disposed of. The directions contained be carried out within a period of 60 days from the date of receipt of certified copy of this order.

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