A probationer lacks an indefeasible right to continued employment. Professional medical assessments regarding fitness for service, performed by expert boards, are generally excluded from judicial interference under writ jurisdiction unless proven to be arbitrary, mala fide, or clearly perverse.

JUDGMENT :

ANIL KSHETARPAL, J.

1. By way of the present Petition, the Petitioner seeks issuance of a writ in the nature of Certiorari for quashing of the termination order dated 20.01.2026 ['Impugned Order'] issued by the Respondent No.2 whereby the services of the Petitioner, who was engaged as Constable (GD) in the Central Industrial Security Force ['CISF'], have been brought to an end during the period of probation. The Petitioner also seeks consequential reliefs including reinstatement in service and other ancillary benefits.

FACTUAL MATRIX

2. In order to appreciate the controversy involved in the present Petition, the relevant facts, in brief, are required to be noticed.

3. The petitioner was selected pursuant to a recruitment process conducted for appointment to the post of Constable (GD) in the CISF. Upon successful completion of the recruitment stages, including written examination, physical efficiency test, and medical examination, the Petitioner was issued an offer of appointment and joined the CISF on 21.06.2021. In terms of the applicable service conditions, the Petitioner was placed on probation. It is not in dispute that the Petitioner continued to serve on probation as original period was extended.

4. It is the case of the Petitioner that during the course of basic training at Regional Training Centre ['RTC'], Bhilai, he repeatedly complained of loose motion and bleeding per rectum, pursuant to which he reported to the Combined Hospital, Bhilai on 19.07.2021. Upon medical examination, he was referred for specialist consultation and thereafter admitted at NHMMI Narayana Super Speciality Hospital, Raipur on 30.07.2021, where he was diagnosed with Ulcerative Colitis.

5. The material placed on record further indicates that the Petitioner remained under treatment till 31.08.2021. Thereafter, instead of continuing treatment at the said hospital, the Petitioner proceeded to his native place and rejoined the RTC only on 06.05.2022 after remaining away for a considerable period of 248 days i.e., 31.08.2021 to 05.05.2022. Upon rejoining, the Petitioner was again referred for specialist medical examination and evaluation regarding his fitness for basic training.

6. The Petitioner was thereafter subjected to repeated medical examination by duly constituted Standing Medical Boards/Review Medical Boards on various occasions, including on 12.06.2023, 26.03.2024, 09.12.2024 and 16.10.2025. The record indicates that on each such occasion, the Petitioner was found medically unfit for undergoing basic training. The reports placed on record further indicate that ultimately the Petitioner was placed in low medical category S1H1A1P2 (Permanent) E1.

7. It further emerges from the record that owing to the Petitioner's continued medical condition and inability to complete the prescribed training, his period of probation was extended on four occasions, each for a period of six months. Ultimately, the Petitioner was served with the Impugned Order dated 20.01.2026, whereby his services were dispensed with during the probation period by invoking Rule 26(4) of the CISF Rules, 2001 by granting one month's salary in lieu of notice.

SUBMISSIONS OF THE PARTIES

8. Submissions of the Petitioner

8.1. Learned counsel for the Petitioner contended that the Impugned Order is arbitrary an