Court’s Decision
The Bombay High Court allowed writ petitions filed by two young candidates disqualified in the Physical Standard Test (PST) of the Constable (GD) recruitment in Central Armed Police Forces (CAPFs), Special Security Force (SSF), Assam Rifles, and Narcotics Control Bureau. The Court held that Clause 2(d) of the Revised Uniform Guidelines dated 20 May 2015, which mandates rounding off height fractions of 0.5 cm or more to the next higher centimeter, is applicable at the PST stage itself. The disqualification of the petitioners for being marginally below 165 cm was therefore illegal. The Court directed authorities to treat their heights as 165 cm and declare them eligible for the Detailed Medical Examination (DME) .
Facts
The Staff Selection Commission issued a notice dated 5 September 2024 inviting applications for Constable (GD), Rifleman, and Sepoy posts in CAPFs, SSF, Assam Rifles, and the NCB. The recruitment process comprised three stages: (i) Computer-Based Test (CBT), (ii) PST & Physical Efficiency Test (PET), and (iii) Detailed Medical Examination (DME).
The petitioners, aged 21, cleared the CBT and PET successfully and then underwent PST at CRPF, Pune. Their recorded heights were 164.7 cm and 164.6 cm respectively, slightly below the prescribed standard of 165 cm for candidates in the Maratha category. They were disqualified and issued PST rejection slips dated 23 August 2025 and 25 August 2025.
They challenged the disqualification before the High Court, seeking directions to apply Clause 2(d) of the 2015 Guidelines so that their heights could be rounded off to 165 cm, thereby rendering them eligible for the next stage .
Issues
- Whether Clause 2(d) of the Revised Uniform Guidelines dated 20 May 2015, which provides for rounding off of height fractions, applies at the PST stage or only at the DME stage.
- Whether the petitioners’ disqualification for falling short by 0.3 cm and 0.4 cm was legal and valid.
- Whether the petitioners were entitled to be declared eligible for the Detailed Medical Examination despite failing PST.
Petitioner’s Arguments
The petitioners contended that Clause 2(d) of the 2015 Guidelines clearly provides that when measuring height, any fraction less than 0.5 cm is to be ignored, and fractions of 0.5 cm and above are to be rounded off to the next higher cm. Since their heights were 164.7 and 164.6 cm, both should be rounded off to 165 cm, making them eligible.
They argued that disqualifying them despite this guideline was arbitrary, mechanical, and caused grave prejudice to their career prospects. They relied on similar rulings of the Madhya Pradesh High Court (Arun Kalmodiya v. Union of India, WP No. 34269/2024, decided 17 February 2025), the Calcutta High Court (Anuj Bala v. Union of India, WP No. 21766/2025, decided 12 September 2025), and the Punjab & Haryana High Court (Union of India v. Kuldeep, LPA No. 1724/2024, decided 24 July 2024), where courts extended the benefit of rounding off to candidates at PST stage .
Respondent’s Arguments
The respondents argued that rounding off of height fractions under Clause 2(d) applies only at the stage of DME, not at PST. They submitted that the PST Board was correct in recording the exact height and disqualifying candidates who fell short of prescribed standards.
According to them, the petitioners’ reliance on Clause 2(d) was misplaced, as that relaxation was meant to be applied by the medical board during DME, not by PST authorities. They therefore defended the rejection slips and opposed interference by the Court .
Analysis of the Law
The Court examined the 2015 Guidelines and the recruitment scheme. It found that PST is conducted prior to DME, and candidates failing PST cannot reach the DME stage. Clause 2(d) expressly empowers PST Boards to ignore fractions below 0.5 cm and round off 0.5 cm and above.
The Court rejected the respondents’ argument that the relaxation applied only at DME, holding that such an interpretation would defeat the object of Clause 2(d). If relaxation were not applied at PST, many borderline candidates would be disqualified prematurely without ever reaching DME.
The Court stressed that recruitment must be conducted in a fair, just, and reasonable manner, and guidelines must be applied uniformly across all stages .
Precedent Analysis
- Arun Kalmodiya v. Union of India (Madhya Pradesh HC, 17 Feb 2025) – Held that height rounding off applies at PST; candidate entitled to relief.
- Anuj Bala v. Union of India (Calcutta HC, 12 Sept 2025) – Similar principle applied; disqualification on marginal height deficiency set aside.
- Union of India v. Kuldeep (Punjab & Haryana HC, 24 July 2024) – High Court extended rounding-off relaxation to PST stage, rejecting narrow interpretation.
The Bombay High Court relied on these judgments to reinforce its conclusion that petitioners were entitled to rounding off at PST .
Court’s Reasoning
The Court found that:
- Petitioners were disqualified for being short by 0.3 cm and 0.4 cm, which were exactly the kind of borderline cases Clause 2(d) sought to address.
- Applying Clause 2(d), their recorded heights had to be rounded off to 165 cm, making them eligible.
- Denying the benefit at PST would render the guideline meaningless and deprive candidates of fair consideration.
The Court observed:
“Disqualifying the petitioners at the stage of Physical Standard Test on account of their height being 164.7 cm and 164.6 cm, respectively, is illegal and arbitrary. The benefit of Clause 2(d) must be extended at the PST stage itself.”
Conclusion
The High Court allowed both writ petitions. It directed the authorities to apply Clause 2(d) and treat the petitioners’ heights as 165 cm. Consequently, the rejection slips were set aside, and the petitioners were declared eligible to appear for the Detailed Medical Examination. No order as to costs was passed .
Implications
- Clarifies that height rounding off under CAPF Guidelines applies at PST, preventing arbitrary disqualification of candidates marginally short of standards.
- Reinforces fairness in recruitment to armed forces, especially where candidates are otherwise meritorious.
- Aligns Bombay High Court’s stance with other High Courts, ensuring national uniformity in interpretation.
- Provides relief to many aspirants whose careers could be jeopardized by negligible measurement discrepancies .
FAQs
1. Can height fractions be rounded off during CAPF recruitment?
Yes. Clause 2(d) of the 2015 Guidelines mandates ignoring fractions below 0.5 cm and rounding off 0.5 cm and above to the next higher cm .
2. Does rounding off apply at PST or only at medical examination?
The Bombay High Court held it applies at PST stage itself, ensuring fairness and consistency .
3. What happens to candidates disqualified for being marginally short?
They can seek relief, as courts have consistently held that Clause 2(d) protects borderline candidates from arbitrary rejection .
