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Second Chance Walking Test in Recruitment: What Indian Courts Say
In government job recruitments, particularly for physically demanding roles like forest guards, range forest officers, and Indian Forest Service (IFoS) positions, the walking test is a critical physical endurance requirement. Candidates often face the question: Can I get a second chance if I fail the walking test? This post dives into second chance walking test recruitment practices, drawing from key Indian court judgments to clarify rules, exceptions, and pitfalls.
Physical tests ensure candidates meet job demands, such as covering 25 km in 4 hours for males or 14-16 km for females in forest recruitments. But disputes arise over second attempts, relaxations, and procedural fairness. Courts emphasize adherence to recruitment rules, equality under Articles 14 and 16 of the Constitution, and preventing arbitrariness.
Understanding Walking Tests in Recruitment Rules
Walking tests are standard in forest and police recruitments. For instance:
- Gujarat Subordinate Forest Service Recruitment Rules, 2016 mandate a walking test, with limited reattempts. Candidates failing the first get one more chance, but no further relaxations. (Similar to rules in other states) KARANTI GOYAL Vs MINISTRY OF ENVIRONMENT FORESTS CLIMATE CHANGE & ANR. - 2023 Supreme(Online)(DEL) 1771
- Range Forest Officer Rules, 2008 require 25 km for males/16 km for females in 4 hours. No provision for multiple retests unless specified. Gadhavi Narendrakumar Hinglajdanji VS State Of Gujarat - 2022 Supreme(Guj) 811
Rules typically allow one second chance for general candidates who fail initially, often without stipend in training contexts. However, courts scrutinize deviations. (The Rules do not permit any relaxation except that the candidates failing to complete the walking test in the first chance are given one more chance.) KARANTI GOYAL Vs MINISTRY OF ENVIRONMENT FORESTS CLIMATE CHANGE & ANR. - 2023 Supreme(Online)(DEL) 1771
Common Scenarios in Forest Service Recruitments
- Initial Failure and Retest: Many rules permit a second walking test. In Manipur Forest Service (2013), ST candidates unfit initially got a retest for their category vacancy. Thokchom Autumn Meitei VS Manipur Public Service Commission through its Secretary - 2016 Supreme(Manipur) 35
- No Extra Chances Post-Second Failure: In Gujarat Forest Guard cases, failing the second test ends eligibility. Re-scheduling requests were dismissed as the process must conclude for finality. (The completion of the recruitment process and appointments given to selected candidates rendered the appellant's request for re-scheduling the walking test infructuous.) Rahulkumar Rameshbhai Rathva VS State Of Gujarat - 2023 Supreme(Guj) 480
Court Rulings on Second Chance Validity
Indian High Courts and Tribunals have ruled consistently: Second chances must align with notified rules. Arbitrary extras violate equality.
Cases Rejecting Unauthorized Second Tests
- In M.P. Class III Forest Recruitment (1999), conducting a second walk test for failed candidates was disapproved. The court deemed it impermissible, especially with revaluation issues, directing appointment to meritorious petitioners. (The court disapproved the action of conducting a second walk test for failed candidates.) Jakir Khan VS State Of M. P. - 2016 Supreme(MP) 963
- Range Forest Officer (Gujarat, 2008): Appointments post an unnotified second test were invalid. Petitioners clearing first test got priority on seniority. (appointments can be inferred to be contrary to rules, inasmuch as, their selection/appointment post second test which was never contemplated in rules) Gadhavi Narendrakumar Hinglajdanji VS State Of Gujarat - 2022 Supreme(Guj) 811
Category-Based Relaxations: Limited Scope
Relaxations are category-specific and can't spill over:
- ST Candidates in Manipur (2013): Extra chance valid only for ST vacancy, not unreserved posts. Extending it violates Articles 14/16. (relaxation granted to ST candidates for filling up of vacancy under ST category is valid but the same cannot be extended to other categories) Thokchom Autumn Meitei VS Manipur Public Service Commission through its Secretary - 2016 Supreme(Manipur) 35
- OBC in M.P. Forest Guard: No second test for others; meritorious OBC candidate reinstated over less-qualified selectee. Costs imposed on department. Jakir Khan VS State Of M. P. - 2016 Supreme(MP) 963
IFoS and Disability Claims
- Indian Forest Service (2014): Visually impaired candidate failed walking test despite second chance. No exemption; rules apply uniformly. Participation waives post-failure challenges. (candidates cannot challenge the rules of a selection process after participating in it) Karanti Goyal VS Ministry of Environment Forests Climate Change - 2023 Supreme(Del) 1998
Procedural Fairness and Finality
Courts stress finality post-process completion:
- Gujarat Forest Guard (2022): Second test for wait-listed candidates only; regular process closed. No re-scheduling. Rahulkumar Rameshbhai Rathva VS State Of Gujarat - 2023 Supreme(Guj) 480
- Kerala PSC Range Forest Officer: Post-notification changes to criteria (e.g., marking) arbitrary. Stick to original rules. THE KERALA PUBLIC SERVICE COMMISSION., vs PRASAD P.S., - 2023 Supreme(Online)(KER) 30346
In Tamil Nadu Forest Apprentice, reservation applies at final selection, not interim shortlisting. 100-point roster over 200-point for fairness. Ranjithkumar VS Secretary, Tamil Nadu Public Service Commission - 2013 Supreme(Mad) 84
Key Principle: Rule of reservation shall be applied only at the time of final selection and not at every stage. Ranjithkumar VS Secretary, Tamil Nadu Public Service Commission - 2013 Supreme(Mad) 84
Broader Recruitment Lessons
From cases like Gujarat Police Sub-Inspector, eligibility (e.g., 3 years as Head Constable) strictly enforced; no shortcuts. Ajra Himmatkumar Naranbhai VS State of Gujarat - 2009 Supreme(Guj) 707
In training contexts (e.g., Railways), SC/ST get up to third chance without stipend, but failure leads to termination. Provisional appointments hinge on passing. Union Of India VS Alok Kumar - 2025 Supreme(SC) 1661
Backdoor Appointments Warning: Ad-hoc hires without process deprive eligible youth; courts quash them. Against Corruption & Unabated Taxation (ACAUT) VS State of Nagaland - 2018 Supreme(Gau) 1573
Key Takeaways for Candidates
- Check Rules Pre-Application: Confirm second chance provisions.
- One Retest Typical: General/OBC: Second chance sans stipend; SC/ST: Possible third.
- No Arbitrary Extras: Courts invalidate unnotified retests.
- Category Limits: Relaxations don't crossover.
- Challenge Timely: Post-appointment finality hard to overturn.
| Scenario | Second Chance Allowed? | Court View |
|----------|-------------------------|------------|
| General Failure | Yes, once | Standard, if notified KARANTI GOYAL Vs MINISTRY OF ENVIRONMENT FORESTS CLIMATE CHANGE & ANR. - 2023 Supreme(Online)(DEL) 1771 |
| ST for UR Post | No | Violates equality Thokchom Autumn Meitei VS Manipur Public Service Commission through its Secretary - 2016 Supreme(Manipur) 35 |
| Unauthorized Retest | No | Invalid appointments Gadhavi Narendrakumar Hinglajdanji VS State Of Gujarat - 2022 Supreme(Guj) 811 |
| Post-Process Request | No | Finality prevails Rahulkumar Rameshbhai Rathva VS State Of Gujarat - 2023 Supreme(Guj) 480 |
Conclusion
Second chance walking test recruitment is rule-bound, with courts safeguarding merit and equality. While a retest offers fairness, exceeding rules invites quashing. Always verify notifications and prepare rigorously.
This post provides general insights from public judgments. Legal outcomes vary by facts; consult a lawyer for advice. Not legal advice.
Search Results for "Second Chance Walking Test in Recruitment: Key Rulings"
1981 0 Supreme(SC) 511 • India - Supreme Court
A.C.GUPTA, V.D.TULZAPURKAR, S.MURTAZA FAZAL ALI, R.S.PATHAK, P.N.BHAGWATI, D.A.DESAI, E.S.VENKATARAMIAH
I hasten to add, that the Solicitor-General is not at all responsible, though on occasions he was required to do some tightrope walking ... Chance remarks came to my knowledge about his conduct in Court as well as about his integrity. ... Chance remarks came to my knowledge about his conduct in Court as well as about his integrity.
1979 0 Supreme(SC) 496 • India - Supreme Court
A.D.KOSHAL, D.A.DESAI, V.R.KRISHNA IYER
Thereafter workers who will not have reported for work shall have no chance left for re-employment with us. ... Hot upon the receipt of the Sabhas letter accepting the offer the Management back-tracked or had second thoughts on full re-employment ... No inquest into the Management's recruitment of fresh hands is being made at this stage.
1963 0 Supreme(SC) 215 • India - Supreme Court
J.R.MUDHOLKAR, K.SUBBA RAO, N.RAJAGOPALA AYYANGAR, RAGHUBAR DAYAL, S.R.DASS, S.K.DAS
At that time the Punjab Civil Medical Services, Class I (Recruitment and Conditions of Service) Rules, 1940, hereinafter called the ... The second head of this item relates to the supply of the sewing machines. ... The second ground of challenge was that these orders, assuming them to be within the power of Government on a proper interpretation
1980 0 Supreme(SC) 494 • India - Supreme Court
O.CHHINNAPPA REDDY, R.S.PATHAK, V.R.KRISHNA IYER
The first is the right to equal treatment, which is the right to an equal distribution of some opportunity or resource, and the second ... Likewise. where direct recruitment, otherwise than by examination, was provided for, taking of SC & ST candidates. ... They are the lower categories where the members of the SC & ST have a chance.
2008 3 Supreme 331 • India - Supreme Court
DALVEER BHANDARI, R.V.RAVEENDRAN, K.G.BALAKRISHNAN, ARIJIT PASAYAT, C.K.THAKKER
layer OBCs and non-creamy layer OBCs are not equals when it comes to moving up the socio-economic ladder by means of educational opportunity ... Merit must be the test when choosing the best, according to this rule of equal chance for equal marks. ... The second test asks which provision came into effect at a later date (i.e., was “later in time?”)? ... The moment we encourage the second-rate, we are lost.
2022 0 Supreme(Guj) 811 • India - Gujarat
walking test, appointments can be inferred to be contrary to rules, inasmuch as, their selection/appointment post second test which ... rules providing for a second walking test – Question therefore will now have to be addressed only from view point of angle of seniority ... in cadre of Range Forest Officers – Admittedly, petitioners have been appointed on basis of they having cleared their walking test ... would indicate that there....
2016 0 Supreme(Manipur) 35 • India - Manipur
N.KOTISWAR SINGH
The court held that considering ST candidates who had been given another opportunity to reappear in the physical test/walking test ... The ST candidate was initially found unfit in the physical test but was later allowed to reappear in the test and was found fit. ... MANIPUR FOREST SERVICE GRADE-II (ASSISTANT CONSERVATOR OF FOREST) EXAMINATION 2013 - APPOINTMENT - RELAXATION OF PHYSICAL FITNESS ... unreserved category by a candidate who was given a second#HL....
2016 0 Supreme(MP) 963 • India - Madhya Pradesh
SUJOY PAUL
Class III Forest (Non Ministerial) Recruitment Rules, 1999, M.P. ... Forest Guard Selection - Recruitment Rules of 1999 - [OBC] - [M.P. ... The court disapproved the action of conducting a second walk test for failed candidates. ... He further admits that for certain candidates, second chance of walking test was given. ... This second examination/walking test is wholly impermissi....
2023 0 Supreme(Del) 1998 • India - Delhi
V. KAMESWAR RAO, ANOOP KUMAR MENDIRATTA
test required for the Indian Forest Service Examination, 2014. ... The court also noted that the Rules of 2014, including the walking test requirement, were applicable to all candidates and had not ... Finding of the Court: The court found that the petitioner's failure to complete the walking test within the stipulated ... The Recruitment Rules for IFoS, stipulate a walking test of 25 kilometers of distance to be covered in four h....
2011 0 Supreme(Gau) 815 • India - Gauhati
A.K.GOSWAMI
appropriate steps are directed to be taken respondents for filling up posts meant for direct recruitment without any delay - Petition ... basis was made due to compelling necessity respondents are also directed to fill up ten posts in accordance with law way of direct recruitment ... Constitution of India – 1950 - Article 226 - Nagaland Industries Service Rules – 1986 - Employment – Appointment ... While the document at Annexure X contains two paragraphs, the document at Annexure Y does not contain the second paragraph. ....
2022 0 Supreme(Guj) 811 • India - Gujarat
by some respondents asking for a second chance was misconceived and the provision of a second chance provided in the Recruitment Rules of Indian Forest Service cannot be compared with the Recruitment Rules of Gujarat Forest Service. ... 5.8 Mr.Mehta, learned Senior Advocate, would further submit that reading of Rule 5 of the Recruitment Rules would indicate that there was no second chance provided for a walking #H....
2016 0 Supreme(MP) 963 • India - Madhya Pradesh
SUJOY PAUL
He further admits that for certain candidates, second chance of walking test was given. In the main select list, petitioner's name does not find place. Petitioner has secured less than cut-off marks. Selection alone does not confer any right. ... For the same reasons, it is urged that second examination needs to be declared as illegal. He placed reliance on a letter dated 10.07.2008 on the strength of which second walking test was conducted. ... inst....
2025 0 Supreme(SC) 1661 • India - Supreme Court
J. K. MAHESHWARI, VIJAY BISHNOI
As per the various Circulars issued by the Appellants from time to time, any trainees belonging to General and OBC categories, who fail to clear such examination in the first chance, can be given a second chance subject to non-payment of stipend. ... In cases of candidates belonging to SC/ST categories, a second attempt can be provided with stipend and such candidates are also entitled to a third chance to clear the training without stipend. ... When the Respondent appeared in the examination after avai....
2023 Supreme(Online)(DEL) 1771 • India - High Court of Delhi
The Rules do not permit any relaxation except that the candidates failing to complete the walking test in the first chance are given one more chance. Since the petitioner failed to complete the walking test, he was given one more opportunity. ... The Recruitment Rules for IFoS, stipulate a walking test of 25 kilometers of distance to be covered in four hours by male candidates and 14 kilometers in four hours by female candidates. T....
2023 0 Supreme(Del) 1998 • India - Delhi
V. KAMESWAR RAO, ANOOP KUMAR MENDIRATTA
The Rules do not permit any relaxation except that the candidates failing to complete the walking test in the first chance are given one more chance. Since the petitioner failed to complete the walking test, he was given one more opportunity. ... The Recruitment Rules for IFoS, stipulate a walking test of 25 kilometers of distance to be covered in four hours by male candidates and 14 kilometers in four hours by female candidates. Th....
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