Focus on Ability, Not Disability: Madras High Court Quashes Rejection of CRPF Candidate with Polydactyly, Citing RPwD Act - 2025-07-24

Madras HC Champions Humanitarian Approach, Quashes CRPF's Rejection of Candidate with Polydactyly

Chennai: In a significant ruling championing a humanitarian approach over rigid technicalities, the Madras High Court has quashed the medical disqualification of a candidate rejected for the post of Constable in the Central Armed Police Forces (CAPFs) on the grounds of having an extra thumb (polydactyly). Justice Vivek Kumar Singh directed the authorities to re-conduct the medical examination, emphasizing that the focus should be on a candidate's ability to perform their duties, not on minor physical defects.

Case Background

The petitioner, R. Balamurugan, successfully cleared the computer-based test, physical standard test, and physical efficiency test for the post of Constable, as per a recruitment notification from November 2023. However, he was declared medically unfit during the detailed medical examination due to "polydactyl on left hand." A subsequent Review Medical Examination held on October 7, 2024, upheld this decision, leading the petitioner to challenge it in the High Court.

Arguments Presented

Petitioner's Stance: The petitioner's counsel, Mr. D. Shanmugaraja Sethupathi, argued that the condition was merely an "unsized thumb" and not polydactyly. He contended that the rejection violated the principles of natural justice. Critically, he pointed to Clause 7 of the 2021 Revised Uniformed Guidelines for Review Medical Examination, which allows the medical board to accept candidates with "minor acceptable defects" if the defect does not affect their efficiency. He also noted that the petitioner was declared medically fit in a similar selection process in 2022-2023, suggesting the current finding was fallacious.

Respondents' Stance: The Central Government Standing Counsel, Mr. J.Alaguram Jothi, countered that the petitioner was indeed unfit due to "pre-axial polydactyl" as confirmed by X-ray and Doppler scans. He argued that Clause 6(27) of the guidelines explicitly lists polydactyly as a ground for rejection. The counsel stated that such anatomical variations could interfere with vital operational tasks like weapon handling and wearing combat gear, posing a risk to personal and unit safety. He cited a Delhi High Court decision in Hemant Kumar Vs. Staff Selection Commission (2018) , where a similar rejection based on the same guideline was upheld.

Court's Reasoning and Observations

Justice Vivek Kumar Singh, after considering the arguments, took a broader, more humane perspective. The court observed that the core issue was whether the defect would actually impede the candidate's performance.

The judgment highlighted several key principles:

1. Humanitarian Approach Over Technicality: The court stated, "...we should see that if once disabled, it is an act of God but not a human error... instead of going to the technicality of the medical disability, they should rather see it on humanitarian approach."

1. Focus on Functional Ability: The court emphasized that if a person with a disability can perform the same duties as a "normal person," their candidature should not be rejected on that sole ground.

2. Principle of 'Reasonable Accommodation': The judgment extensively referenced the Persons with Disabilities (RPwD) Act, 2016, and the principle of "reasonable accommodation." It noted that denying a job is permissible only if the disability prevents the person from performing the functions associated with it. The court cited the Supreme Court's decision in Vikash Kumar v. Union Public Service Commission (2021) , which established reasonable accommodation as a key to realizing constitutional guarantees of equality and dignity for persons with disabilities.

"Looking from any angle, denying a job citing disability can only be allowed if the disability prevents the person from performing the functions associated with the job," the Court observed.

The Final Verdict

Finding merit in the petitioner's case and aligning its decision with precedents that favoured candidates in similar situations, the High Court allowed the writ petition. The impugned review medical examination report dated October 7, 2024, was quashed. The court has directed the respondents to review and re-conduct the medical examination for Mr. Balamurugan, taking into account the principles laid down in its judgment.