Medical examinations are often the final hurdle in public recruitment, particularly for appointments to the armed forces, uniformed services and other physically demanding roles. Candidates who have cleared the written, mains and physical examinations may nevertheless be rejected at the detailed or review medical examination. Such decisions can cause significant hardship and raise concerns about the protection of fundamental rights, including equality before the law, personal liberty and the freedom to pursue a profession under Articles 14, 16, 19 and 21 of the Constitution of India¹.

The central concern is whether each medical standard bears a rational connection to the duties of the post and is necessary to achieve its objectives. A candidate may, for instance, fall short of a prescribed height or other physical criterion while remaining fully capable of performing the role's essential functions. Where a standard does not materially affect job performance, its application may result in arbitrary exclusion. Indian constitutional courts have addressed these issues, examining the justification, fairness and proportionality of medical fitness requirements in public appointments.

Judicial Scrutiny Of Medical Disqualification And The Duty To Accommodate

Recent decisions of Indian constitutional courts reflect an important principle related to medical standards for public appointments, wherein it has held that these principles should be applied in light of the duties and essential requirements of the particular post. A medical finding should not become an automatic ground for exclusion. Rather, the decision-making authority must consider whether the identified condition has a demonstrable bearing on the candidate's ability to perform the role, and whether the governing medical standard has been properly applied. It has been seen that in number of cases, Courts have held that report not just arbitrarily elaborate on the deformity possessed by the candidates, but also backed by the opinion of experts that whether such deformity would affect the performance of the duties related to the post for which such person is applying.

This approach is evident in Nishant v. Union of India². The Delhi High Court examined the medical guidelines relating to deformities of the toes and observed that the mere presence of such a deformity was not, by itself, sufficient to disqualify a candidate. Under the relevant provision, disqualification depended on whether the deformity prevented the proper wearing of combatised footwear or impaired the candidate's ability to walk, march, run or jump. The Court noted that the Review Medical Board's report did not indicate that it had considered these functional requirements before declaring the candidate unfit. The judgment thus emphasises that medical assessments must address the criteria set out in the applicable guidelines and explain how the candidate's condition affects the functions relevant to the post.

A related, broader approach was adopted by the Madurai Bench of the Madras High Court in R. Balamurugan v. DG, CRPF.³ The case concerned a candidate with polydactyly of the left thumb. The Court observed that a minor deformity that does not significantly impair a candidate's ability to perform the duties of the post should not, on that ground alone, stand in the way of selection. Its reasoning directs attention away from the diagnosis in isolation and towards the candidate's functional capacity: the relevant question is whether the condition prevents the performance of the essential duties, not simply whether the candidate differs from a medical norm.

The Court also situated this functional approach within the constitutional commitment to equality, non-discrimination and dignity, and referred to the Rights of Persons with Disabilities Act, 2016⁴. The Act defines “reasonable accommodation” as necessary and appropriate modifications or adjustments that do not impose a disproportionate or undue burden and enable persons with disabilities to enjoy or exercise their rights equally with others.⁵ Drawing on the Supreme Court's decisions in Jeeja Ghosh v. Union of India⁶ and Vikash Kumar v. Union Public Service Commission⁷, the judgment recognised reasonable accommodation as a means of making the constitutional guarantees of equality and non-discrimination meaningful in practice.

The Government in this direction have made certain changes in their approach in dealing with this issue. Government of India guidelines for medical examinations in the Central Armed Police Forces and Assam Rifles⁸ require rejection decisions to be supported by specific clinical findings and, where appropriate, confirmatory tests or specialist opinions. The 2021 amendment⁹ in 2015 Guidelines cautions against rejection based solely on clinical observation and says that necessary investigations should be completed before a decision is made. The 2015 guidelines require medical officers to record the relevant measurements and standards, describe the location and extent of any defect, and note minor defects that are not expected to affect a candidate's ability to perform their duties. They also permit medical officers to use their judgment for conditions not expressly listed, and to refer doubtful cases for specialist assessment or further tests.

However, the use of these discretionary powers by the authorities are not supported by sufficiently clear standard operating procedures. This can lead to inconsistent or arbitrary decisions and undermine the fair and impartial application of the medical standards vis-à-vis the objective of the recruitment, which has affected the impartial implementation of these parameters.

Taken together, these decisions support a more individualised and evidence-based process for assessing medical fitness. They do not imply that every medical standard is irrelevant or that every condition must be accommodated in every role. Rather, they call for authorities to apply the standards prescribed for the post, assess the candidate's ability to perform its essential functions, and provide clear reasons where a condition is said to make the candidate unfit. This approach helps distinguish a genuine, job-related limitation from a medical difference that has no material effect on performance and guards against exclusion based solely on diagnosis, appearance or technical classification.

Taken together, the judgments and Government guidelines establish that medical fitness assessments for public appointments should be post-specific, evidence-based and focused on the candidate's ability to perform the role's essential duties. A diagnosis or physical difference should not, by itself, determine fitness: any finding of unfitness should identify the applicable standard, explain the condition's functional impact and, where necessary, be supported by appropriate investigations or expert opinion. This approach preserves legitimate service requirements while giving effect to equality, dignity and non-discrimination.

To ensure that these principles are applied consistently, clear standard operating procedures should guide medical and review boards in exercising their discretion. Such procedures should require reasoned findings, consideration of relevant functional criteria and appropriate specialist assessment in doubtful cases. A transparent and uniform process would reduce arbitrary outcomes and help distinguish genuine job-related limitations from conditions that do not materially affect performance.

End Notes & References: 

1. The Constitution of India, art. 14, 16, 19 & 21.

2. Nishant v. Union of India & Ors, 2025: DHC:956-DB

3. R. Balamurugan v. DG, CRPF3, 2025: MHC:1655.

4. The Rights of Persons with Disabilities Act, 2016 (Act 49 of 2016).

5. The Rights of Persons with Disabilities Act, 2016 (Act 49 of 2016), s.2(y).

6. Jeeja Ghosh v. Union of India, AIR 2016 SC 2393.

7. Vikash Kumar v. Union Public Service Commission, AIR 2021 SC 2447.

8. Government of India Guidelines for Medical Examinations in the Central Armed Police Forces and Assam Rifles, 2015.

9. Revised Uniform Guidelines for Review Medical Examination in Central Armed Police Forces and Assam Rifles for Gos & NGOs: Amendment Thereof, 2021.

Author is an Advocate practicing at Supreme Court of India and Delhi High Court. Views are personal.