Court Does Not Sit In Appeal Over Medical Expert's Opinion, Interference Permitted Only In Case Of Arbitrariness: Calcutta High Court

Brief Facts:

The petitioner, an aspirant in the CAPFs (GD) Examination 2024, advanced to the Physical Efficiency Test stage but was disqualified during the Medical Examination on October 7, 2024, due to “Clubbing of Fingers – both hands.”

He subsequently applied for a Review Medical Test, conducted on October 14, 2024, which reaffirmed the same ground for disqualification. However, a subsequent examination at a government medical center in West Bengal on October 23, 2024, certified that while clubbing was present, the petitioner's hands were otherwise normal.

However, in view of the concurrent finding by the first Medical Board and the Review Medical Board of the selection authority the candidature of 3 the petitioner was rejected. Being aggrieved with such rejection the petitioner has filed the instant writ petition.

Contentions:

The petitioner submitted that nowhere from the said medical guideline it would appear that Clubbing of Fingers at the hands will be treated as a disqualification for a candidate. Referring to the clauses, it was submitted that Clubbing of Feet has been mentioned to be a disqualification under the medical guidelines but there is no whisper that Clubbing of Fingers at the hands will be a disqualifying criteria.

It was also argued that the Rule of the Game is fixed. The disqualifications are also fixed there under. Unless a specific disqualification is mentioned in the medical guideline, no candidature can be rejected on such flimsy ground which is not a disqualification under the medical guidelines.

Per contra, the Respondent submitted that the medical boards consisting of the medical experts have arrived at their specific finding at both the levels of medical tests that, the petitioner has clubbing of fingers at the hands and the petitioner was found to be disqualified being medically unfit for the selection process.

Lastly, it was submitted that the medical guidelines, framed by experts, provide that scars or deformities affecting the normal functioning or free movement of fingers/hands to a degree that interferes with duty performance shall result in disqualification. Based on this clause and the physical examination findings, the medical boards rightly disqualified the petitioner. Their decisions were just, proper, and strictly in line with the prescribed medical standards, with no trace of illegality or arbitrariness.

Observations:

The court at the outset noted that a meaningful and harmonious reading of Sub-Clause (c) to Clause 3 of the medical guidelines makes it clear that scars or deformities of the fingers or hands that impair normal functioning or free movement to the extent of interfering with satisfactory performance of combatised duties constitute a disqualification.

It further added that in the petitioner's case, the medical experts noted clubbing of fingers and, based on that observation, concluded it warranted disqualification. Even if the medical reports did not expressly state that the clubbing would impair performance, the absence of such specific wording is inconsequential, given the reports were prepared by qualified medical professionals exercising their expert judgment.

The court also observed that the factual findings and the decision of rejection in the medical reports are sufficient and fully compliant with the disqualification criteria set out in the medical guidelines. Upon reviewing Sub-Clause (c) to Clause 3, it was held that the reason cited—clubbing of fingers—is squarely covered under this provision. Accordingly, the petitioner's claim that the ground for disqualification is not mentioned in the medical guidelines is without merit and was rejected.

It further said that the decision for rejection taken by the medical experts is justified, lawful, and in full compliance with the medical guidelines, requiring no interference by this Court.

The court concluded that the Court does not sit in appeal over expert opinions or substitute its views for those of experts. Judicial interference is warranted only when there is clear mala fide intent, arbitrariness, or inconsistency on the face of the expert opinion—none of which are present in this case.

Accordingly, the present petition was dismissed.

Case Title: Joni Sk Vs. Union of India & Ors.

Case Number: W.P.A. 27189 of 2024

Judgment Date: 21/05/2025

For the petitioner : Mr. Bikash Ranjan Bhattacharya, Sr. Advocate Mr. Siddhartha Sankar Mandal Ms. Arunima Das Sharma

For the UOI :Mr. Subhankar Chakraborty Mr. Pradyat Saha Ms. Ruchira Manna

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