Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(Del) 1283

IN THE HIGH COURT OF DELHI AT NEW DELHI
Kameswar Rao, Manmeet Pritam Singh Arora, JJ
Priyanshu Raj – Appellant
Versus
Union Of India – Respondent
W.P.(C) 18334/2025|CM APPL. 75914/2025|CM APPL. 79175/2025

Advocates:
For the Appellants/Petitioners: Moksh Arora, Manish Kumar Srivastava, Hardik Vashisht
For the Respondents: Jagdish Chandra Solanki, Siddharth Bajaj, Maanya Saxena, Ravinder Agarwal, Manish Kumar Singh, Vasu Agarwal, Shekhar Vya, Neha Warrier

Rounding off guidelines for physical height measurements in recruitment processes must be applied during the initial physical standard testing stage to ensure fair and accurate assessment, rather than being restricted solely to later medical evaluation stages, thereby preventing the arbitrary exclusion of eligible candidates.

Headnote:(A) Constitution of India - Articles 226 and 227 - Writ jurisdiction - Recruitment process - Physical standard test - Minimum height requirement - Whether rounding off of height measurement is permissible at the initial screening stage - Guidelines stipulate that a height fraction of 0.5 cm or more be rounded off to the next higher centimeter - Held, such rounding off constitutes a standard measurement principle and must be applied at the initial stage to ensure administrative fairness, rather than limiting it solely to a subsequent medical evaluation. (Paras 12, 13)

(B) Administrative Law - Recruitment policies - Construction of guidelines - Clauses providing for the rounding off of physical measurements are not auxiliary to medical assessment but function as independent standards for accurate measurement - Excluding the application of this clause at the initial stage negates the intended purpose of the policy. (Paras 13, 14)

Facts of the case:
The petitioner, an aspirant for a service position, was disqualified during the physical standard test because the recorded height fell short of the prescribed minimum by a marginal fraction. The petitioner challenged the rejection, relying on internal recruitment guidelines that allow for the rounding off of height measurements of 0.5 cm or more to the next centimeter.

Findings of Court:
The court determined that the guidelines concerning height measurement were intended to provide a uniform standard for assessment across all stages of recruitment. Restricting the benefit of rounding off to the later medical examination stage would effectively cause the unnecessary exclusion of compliant candidates at the threshold. Consequently, the court held that these measurement guidelines must be applied at the initial stage of physical testing.

Issues: Whether the recruitment policy allowing for the rounding off of fractional height measurements is applicable during the initial physical standard test or if such guidance is strictly limited to the later detailed medical examination.

Ratio Decidendi: The guideline regarding the rounding off of fractional height is a procedural rule for measurement, not a medical test, and must apply whenever a physical measurement is officially recorded. This ensures that candidates are objectively evaluated against their actual standard height, preventing arbitrary disqualification.

Result: Petition allowed.

Table of Content
1. factual background leading to the current challenge of the rejection slip. (Para 1 , 2 , 3)
2. are physical measurement relaxations applicable at the physical standard test (pst) stage? (Para 4 , 5 , 10 , 11)
3. statutory standards and specific measurement discrepancies in the case. (Para 6 , 7 , 8 , 9)
4. interpreting clause 2(d) of the 2015 recruitment guidelines regarding height rounding. (Para 12 , 13 , 14)
5. analysis of competing high court precedents regarding relaxation applicability. (Para 15 , 16 , 17 , 18)
6. final direction allowing the petition based on valid height rounding. (Para 19 , 20 , 21)

1. The present writ petition has been filed under Article 226 and 227 of the Constitution of India for issuance of an appropriate writ, order or direction thereby setting aside the Physical Standard Test (‘PST’) rejection slip dated 17.11.2025 disqualifying Petitioner from appearing for Physical Efficiency Test (‘PET’) in Central Armed Police Forces (Assistant Commandants), Examination 2025 and declare the Petitioner eligible for PET by extending the benefit of relaxation to Petitioner as contemplated under Clause 2(d) of the Revised Guidelines for Recruitment Medical Examination in Central Armed Police Forces and Assam Rifles dated 20.05.2015 (as revised on 31.05.2021)[‘Guidelines’].

2. The relevant facts in brief as set out in the petition are as under:

2.1 Petitioner is a person interested in the post of Assistant Commandant in Central Armed Police Forces 2025.

2.2 The Respondent No. 1 is the Ministry of Home Affairs who published Rules for the examination process in Gazette of India dated 05.03.2025 as issued by Respondent No. 2/UPSC and invited applications. Respondent No. 3 is the offices of Directorate General, ITBP who had issued Admit card directing Petitioner to appear before Respondent No. 4 on 17.11.2025 for PST/PET. Respondent no. 4 issued the PST Rejection Slip dated 17.11.2025 to the Petitioner.

2.3 Government of India, Ministry of Home Affairs, vide Office Memorandum bearing No. A.VI- 1/2014-Rectt (SSB) dated 20.05.2015 as revised vide MHA UO No. E- 32012/ADG(Med)/DME&RME/ DA-1/2020 (Part File)/1166 dated 31.05.2021, had approved the Guidelines for Recruitment Medical Examination in CAPFs & AR, for implementation.

2.4 Respondent No.2 vide Examination Notice dated 05.03.2025 bearing no. 09/2025-CAPF (‘Notice’), invited applications from eligible candidates, for the post of Assistant Commandants in Central Armed Police Forces viz. Border Security Force, Central Reserve Police Force, Central Industrial Security Force, Indo-Tibetan Border Police and Sashastra Seema Bal. Said Notice prescribed various stages for the recruitment of the candidate(s) for the said post, such as (a) written examination, (b) Physical Standard Test (PST)/ Physical Efficiency Test (PET), (c) Interview/Personality Test and (d) Medical Standards Tests.

2.5 Petitioner, on 03.08.2025, being eligible and satisfying the requisite qualifications prescribed in the said Notice applied for the said post under General Category. Admit card bearing Roll No. 0800642 was issued to Petitioner to appear for the written examination on 03.08.2025.

2.6 Petitioner vide results dated 10.10.2025 was declared qualified in the Written Examination.

2.7 Thereafter, Petitioner duly appeared before Respondent No. 4 for the PST on 17.11.2025 and was declared disqualified in the said test on the ground that the height of petitioner was “Less In Height” i.e., less than the standard height [165 cm], prescribed in the said Notice.

2.8 Learned counsel for the Petitioner states that the Petitioner’s height is 164.6 cm as confirmed by virtue of General OPD Card cum Certificate dated 27.11.2025 as issued by one Dr. Arun Khatri, M.B.B.S M.D. (Internal Medicine), Sushila Hospital, Narela, Delhi.

2.9 Being aggrieved by impugned PST rejection slip dated 17.11.2025, Petitioner filed the present writ petition.

3. The Court vide order dated 03.12.2025 after recording

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2026 Supreme(Online)(Del) 1283

IN THE HIGH COURT OF DELHI AT NEW DELHIKameswar Rao, Manmeet Pritam Singh Arora, JJPriyanshu Raj – AppellantVersusUnion Of India – RespondentW.P.(C) 18334/2025|CM APPL. 75914/2025|CM APPL. 79175/2025

IN THE HIGH COURT OF DELHI AT NEW DELHI
Kameswar Rao, Manmeet Pritam Singh Arora, JJ
Priyanshu Raj – Appellant
Versus
Union Of India – Respondent
W.P.(C) 18334/2025|CM APPL. 75914/2025|CM APPL. 79175/2025