Telangana High Court Upholds CRPF Constable's Termination On Depression Diagnosis, Cites Risk From Access To Firearms
The Telangana High Court has upheld the termination of a Central Reserve Police Force (CRPF) constable who was diagnosed with depression and declared medically unfit for basic training and service. It noted that the Review Medical Board had considered the inherent stress of CRPF training and the risk arising from easy access to firearms before recommending his termination. Justice Pulla...
The Telangana High Court has upheld the termination of a Central Reserve Police Force (CRPF) constable who was diagnosed with depression and declared medically unfit for basic training and service.
It noted that the Review Medical Board had considered the inherent stress of CRPF training and the risk arising from easy access to firearms before recommending his termination.
Justice Pulla Karthik held that the constable had been afforded ample opportunity and subjected to repeated medical evaluations before the Review Medical Board recommended his termination. The Court found no fault with the CRPF's decision to terminate his services under Rule 6 of the Central Civil Services (Temporary Service) Rules, 1965.
The Court observed:
“From the above, it is clear that the petitioner was afforded ample opportunity at every stage of proceedings. However, he was not cured well. Further, the Review Medical Board has also taken note of the inherent stress suffered by the petitioner during the basic training in CRPF and also the high risk related to easy access to firearms, which is endanger to the life of the petitioner as well as others, before recommending the termination of the services of the petitioner.”
The petitioner was appointed as a constable in the CRPF in April 2021 and sent to the Recruit Training Centre at Suratgarh for basic training.
According to the CRPF, within six weeks of commencing training, he was admitted to the ATC Hospital at Suratgarh with complaints of excessive negative thoughts, restlessness and mood swings. He subsequently underwent treatment at various hospitals and was prescribed anti-depressants and Benzodiazepines.
He was relegated from basic training and returned to the CRPF Group Centre at Hyderabad. A psychiatric evaluation at the CRPF Composite Hospital in Hyderabad in June 2021 found that he continued to have negative thoughts and diagnosed him with "Mixed Anxiety and Depression". He was provisionally declared unfit for basic training and advised to continue medication.
When reviewed again in August 2021, the psychiatrist found him unfit for basic training and advised continuation of medication.
The petitioner, however, contended that he had sought leave during his training to visit his parents but the request was refused. According to him, the authorities suspected that he was depressed because his leave had not been granted and subjected him to psychiatric examination.
He claimed that a psychiatric test conducted in March 2022 showed him as normal. Despite this, he was transferred to Hyderabad and allegedly made to perform menial work, including watering plants, sweeping and mixing cement and sand.
The petitioner further alleged that on May 10, 2022, he was handed his termination letter at around 8 PM and made to leave the CRPF campus. He argued that no reasons were assigned and no show-cause notice was issued before his termination, in violation of the principles of natural justice.
He subsequently approached the Government Hospital for Mental Care at Erragadda seeking another psychiatric examination. According to him, the hospital informed him that such examination could be conducted only on a reference from the CRPF. His requests to the CRPF authorities seeking such a reference were not accepted, he contended.
The CRPF disputed the petitioner's account. It told the Court that after his earlier examinations, approval was obtained for a Review Medical Examination at the CRPF Composite Hospital in New Delhi.
A Review Medical Board consisting of medical officers, including psychiatrists, was constituted. When the petitioner reported for examination on March 4, 2022, he stated that he had not taken medication for the preceding 40 days and denied having fresh complaints. He initially appeared normal and was admitted for observation without medication. However, according to the CRPF, he subsequently developed uneasiness and discomfort.
He was then referred to Ram Manohar Lohia Hospital, New Delhi, for psychodiagnostic evaluation by a clinical psychologist.
On April 5, 2022, the Review Medical Board considered his treatment records, clinical examination and the psychodiagnostic evaluation from RML Hospital. It concluded that he was suffering from depression and was unfit for CRPF basic training and service.
The Medical Board recorded:
“The psychodiagnostic evaluation of RML Hospital, New Delhi also confirmed the diagnosis of DEPRESSION. DEPRESSION is a major mental illness characterised by stress in basic training and service, personal life and domestic problems. Keeping in view of inherent stress during basic training in CRPF and high risk related to easy access to firearms which is endanger to the lift of himself and others. No. 215145083 Recruit/GD Prasanth K of GC Hyderabad was found unfit for Basic Training and service in CRPF and recommended for termination/invalidation from CRPF as per the rules and regulation of CRPF.”
On the Medical Board's recommendation, the CRPF terminated the petitioner's services with effect from May 10, 2022 under Rule 6 of the CCS (Temporary Service) Rules, 1965.
The CRPF further submitted that the petitioner's appeal against his termination was considered and rejected by the Appellate Authority on August 31, 2023. His subsequent representations were also answered. It argued that there was no provision under the applicable Rules requiring another medical or psychiatric examination.
Considering the medical history, the High Court noted that the petitioner had undergone continuous treatment and repeated psychiatric evaluations. It also took note of the Review Medical Board's finding that the RML Hospital evaluation had confirmed the diagnosis of depression.
The Court found that the Medical Board had specifically considered the inherent stress involved in CRPF basic training and service, as well as the risk associated with access to firearms, before finding the petitioner unfit.
It consequently held that the termination order dated May 10, 2022 "cannot be faulted with" and dismissed the writ petition.
Case Title: Kubeer Prashanth v. Union of India & Ors.
Case No.: W.P. No. 24885 of 2023
Date: August 7, 2026
Appearance: Dr. B. Karthik Navayan for the petitioner; B. Jithender, Central Government Standing Counsel, for Respondent Nos. 1 to 4; Government Pleader for Services-I for Respondent No. 5.