1. Court’s decision
The Delhi High Court has directed the constitution of a fresh Medical Board at the R&R Hospital to reassess a woman candidate who was declared medically unfit for recruitment as Sub-Inspector in Delhi Police and CAPFs. The Court found a clear discrepancy between the findings of the Detailed Medical Examination (DME) and the Review Medical Examination (RME), particularly regarding haemoglobin levels and indications of abnormal peripheral blood smear (PBS) findings.
Relying on its earlier rulings in Staff Selection Commission v. Aman Singh and the Division Bench decision in KM Priyanka v. Union of India, the Court held that when the DME and RME produce inconsistent, contradictory or mutually incompatible medical conclusions, fairness requires that the candidate be assessed afresh by an expert board.
The Court therefore directed the petitioner to appear at R&R Hospital on 22 November 2025 at 11 a.m., ordered the inclusion of a haematologist on the board, required fresh blood testing, and mandated completion of the medical evaluation within one week.
2. Facts
The petitioner participated in the 2024 recruitment process for women candidates for the post of Sub-Inspector in Delhi Police and CAPFs. She cleared all stages except the medical examination.
During the DME, the petitioner was declared unfit due to anaemia, with her haemoglobin level recorded at 9.7 gm%, below the prescribed minimum of 10 gm% for the post.
Aggrieved, she sought a Review Medical Examination. The RME recorded her haemoglobin count as 11.3 gm%, which is above the minimum requirement. However, the RME report declared her unfit, citing:
• abnormal PBS showing immature cells and myeloblasts,
• the need for frequent hospital visits,
• physician’s adverse opinion regarding haematological abnormalities.
These observations related to abnormal blood morphology had not been noted at all in the DME.
The petitioner challenged the disqualification on the ground that the DME and RME findings were materially inconsistent and that the RME had introduced new abnormalities that had never been previously alleged. She sought a direction that she be treated as medically fit.
3. Issues
The High Court considered the following issues:
- Whether contradictory findings between the DME and RME justify ordering a fresh, independent medical evaluation.
- Whether the RME could introduce new grounds of medical unfitness when the DME had recorded only low haemoglobin.
- Whether the petitioner is entitled to a third-level medical assessment to ensure accuracy, fairness and consistency in recruitment-related medical fitness decisions.
4. Petitioner’s arguments
The petitioner argued that the RME report contradicted the DME on the most fundamental parameter: haemoglobin. While DME recorded 9.7 gm%, RME recorded 11.3 gm%—a difference large enough to affect eligibility.
She also argued that the RME’s references to abnormal PBS findings, immature cells and myeloblasts were never raised in the DME, which had only cited anaemia. Introducing new grounds without correlating them to the earlier examination, she submitted, was unjust and arbitrary.
Relying on KM Priyanka and Aman Singh, she contended that when medical reports conflict, the candidate is entitled to assessment by a fresh board. She further argued that the presence of a haematologist on the board is essential given the nature of findings.
5. Respondent’s arguments
The Union of India argued that although the petitioner’s haemoglobin at the RME exceeded the minimum level, she was still medically unfit because the abnormal PBS findings and immature myeloblasts indicated a deeper haematological disorder requiring frequent hospital visits—rendering her unsuitable for armed policing duties.
The respondents maintained that RME is a statutory safeguard and its findings carry greater weight. According to them, the abnormalities justified disqualification even if haemoglobin improved.
However, the respondents could not explain why such critical abnormalities were absent from the DME, nor why both examinations differed so significantly on basic blood parameters.
6. Analysis of the law
The Court reiterated its consistent jurisprudence: wherever the DME and RME differ materially, fairness under Article 14 requires a fresh independent medical evaluation.
In KM Priyanka v. Union of India, the Division Bench held that candidates cannot be denied appointment on the basis of contradictory or inconsistent medical assessments.
In SSC v. Aman Singh, the Court reaffirmed this rule, holding that inconsistencies between DME and RME undermine the reliability of the medical determination and require adjudication by a third board.
Applying these principles, the Court found:
• The haemoglobin discrepancy was significant.
• DME cited only anaemia; RME cited complex haematological abnormalities.
• Both reports could not be reconciled.
Thus, the petitioner was entitled to a fresh, unbiased evaluation by senior specialists.
7. Precedent analysis
The Court relied on two binding precedents:
1. KM Priyanka v. UOI (2020 SCC OnLine Del 1851)
— Inconsistent DME and RME findings require a fresh medical board.
2. SSC v. Aman Singh (2024 SCC OnLine Del 7600)
— Candidates cannot be penalized on the basis of contradictory medical evaluations.
These precedents establish that procedural fairness in recruitment requires consistency, and where inconsistency exists, an additional expert medical board is the only lawful approach.
8. Court’s reasoning
The Court held that the discrepancy between the DME and RME—particularly regarding haemoglobin—could not be ignored. Further, the introduction of serious haematological abnormalities at the RME stage, without any trace in the DME, raised a substantive doubt about accuracy.
The Court concluded:
• The RME cannot override the DME when both give conflicting assessments on material parameters.
• The presence of abnormal PBS findings requires specialist evaluation by a haematologist.
• Fairness and transparency mandate a fresh board.
Thus, the Court directed formation of a specialized medical panel, ensured specialist involvement, and fixed timelines for completion of the process.
9. Conclusion
The writ petition was disposed of with directions:
• A fresh Medical Board shall be constituted by the R&R Hospital, mandatorily including a haematologist.
• The petitioner shall appear before the Medical Superintendent on 22 November 2025 at 11 a.m.
• A fresh blood test shall be conducted before the evaluation.
• If further tests are required, they must be completed before issuing a final opinion.
• The medical evaluation shall be concluded within one week, and results communicated immediately.
• If declared fit, the petitioner’s candidature shall be processed further in accordance with law.
• All legal rights of the petitioner remain reserved.
10. Implications
This ruling strengthens the jurisprudence on fair medical evaluation in recruitment, ensuring that:
• Candidates are protected from arbitrary or contradictory medical disqualification.
• Recruitment authorities must maintain consistency between DME and RME.
• Specialist involvement is necessary when complex medical abnormalities arise.
• Courts will intervene swiftly when procedural fairness is compromised.
The judgment reaffirms that recruitment medical tests must be scientifically accurate, transparent, specialist-backed, and insulated from inconsistency.
Case Law References
KM Priyanka v. Union of India (2020 SCC OnLine Del 1851)
— Held that contradictory DME and RME results require fresh medical evaluation.
Staff Selection Commission v. Aman Singh (2024 SCC OnLine Del 7600)
— Reinforced the requirement of consistency in medical fitness assessments.
FAQs
1. What happens if DME and RME results are contradictory in police or CAPF recruitment?
Courts direct a fresh medical evaluation by an independent board to ensure fairness.
2. Can new medical abnormalities be raised at the RME stage?
Yes, but if these conflict with the DME conclusions, a fresh medical board becomes mandatory.
3. Will a candidate be treated as fit if the fresh board clears her?
Yes. If the new board finds the candidate medically fit, her recruitment is processed normally.
