Satish Khandu Patil and Others v. the Union of India through Ministry of Home Affairs and Others

Bombay HC15 Oct 2025WP/3579/2025

Case brief

AI extract

What is this about?

Biometric mismatch; withheld result; declaration of result; SSC Constable (GD)/Rifleman (GD) recruitment; Advertisement No. 2411 of 2023; CAPFs; Secretariat Security Force; Assam Rifles; BSF; CISF; CRPF; SSB; ITBP; forensic report awaited; Central Forensic Science Laboratory Pune; Staff Selection Commission; Article 226; parity with Bombay High Court Nagpur Bench W.P. Nos. 975, 976, 977 of 2025 (order dated 30.06.2025); results directed to be declared within 4 weeks; Aurangabad Bench; Venegavkar, J.; Kankanwadi, J.

What did the court decide?

Petitions allowed in terms of paragraphs 8, 9 and 10 of the Nagpur Bench order; respondents directed to declare the petitioners' results within 4 weeks from the date of the order; rule made absolute with no order as to costs. ¶¶58

Satish Khandu Patil and Others Vs the Union of India… — Writ and Judicial Review | Bombay HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the respondents are justified in withholding the petitioners' results for the Constable (GD)/Rifleman (GD) recruitment solely on the ground of biometric mismatch, after the petitioners completed all stages of recruitment including medical re-examination while the forensic report remains awaited, and whether directions should issue to publish their results. +1 more

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Court's answer

The present petitions are allowed in terms of paragraphs 8, 9 and 10 of the Nagpur Bench order extracted in this judgment (thereby adopting its directions, including that candidature be considered on merit if otherwise qualified).

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Ratio / Principle

The facts and issues involved in the present petitions are identical to those in Writ Petitions Nos. 975, 976 and 977 of 2025 decided by the division bench of the Bombay High Court, Nagpur Bench on 30 June 2025, and the ratio of that judgment squarely applies to the present case.

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Key takeaways

The respondents are directed to declare the results of the petitioners within 4 weeks from the date of the order.ratio¶¶57

Detailed headnote1 paragraphs

Bombay High Court, Aurangabad Bench (Smt. Vibha Kankanwadi and Hiten S. Venegavkar, JJ.; judgment per Venegavkar, J.), 15 October 2025 — Four writ petitions (W.P. Nos. 12450, 3579, 7994 and 7993 of 2025) under Article 226 by candidates recruited as Constable (GD)/Rifleman (GD) pursuant to Advertisement No. 2411 of 2023 (issued 24.11.2023) for CAPFs, SSF, Assam Rifles, BSF, CISF, CRPF, SSB and ITBP. The petitioners cleared the written examination, PET/PST, document verification and medical re-examination, but their results were withheld solely because of a persistent biometric mismatch not attributable to them, pending a forensic report; the final result for other candidates was published on 14.12.2024. Finding the facts and issues identical to the division bench order dated 30.06.2025 of the Bombay High Court, Nagpur Bench in W.P. Nos. 975–977 of 2025 (whose paragraphs 8–10 were extracted), and with the respondents' counsel conceding similarity of the candidates, the Court held that the ratio of that judgment squarely applied, allowed the petitions in terms of paragraphs 8, 9 and 10 thereof, and directed the respondents to declare the petitioners' results within 4 weeks. Rule made absolute; no order as to costs.

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2025:BHC-AUG:30070-DB

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12450-25-WP (+3).odt

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IN THE HIGH COURT OF JUDICATURE AT BOMBAY BENCH AT AURANGABAD

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WRIT PETITION NO.12450 OF 2025

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Shaikh Sadik Hanif, Age: 22 Years, Occupation: Student, R/o. At Post Telki, Tq. Loha, District: Nanded – 431 707. 2. Gopal Kailas Chavan, Age: 23 years, Occupation : Student, R/o. At post Mandve, Kumbhari Tanda, Tq. Jamner, District Jalgaon. … Petitioners

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Versus

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The Union of India, Ministry of Home affairs, Through, its Secretary, North Block, New Delhi – 110 001.

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The Union of India, Ministry of Personnel Public Grievances & Pensions, Through its Secretary, North Block, New Delhi – 110 001. 3. Central Forensic Science Laboratory, HW4P+HXP Krishna Complex, 38/4, Mundhwa, Kharadi Road, Yashwant Nagar, Kharadi Road, Pune – 411 011. 4. Staff Selection Commission, Through its Chairman, Block No.12, CGO Complex, Lohi Road, New Delhi – 110003. ...Respondents AND

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WRIT PETITION NO.3579 OF 2025

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Satish Khandu Patil, Age: 22 Years, Occupation: Student, R/o. At Post Shirud, Tq. Amalner, District. Jalgaon.

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Nitin Dhanraj Mhaske, Age: 21 Years, Occupation : Student, R/o. At post Anakwadi, Post Purmepada, Dhule, Dist. Dhule.

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Harish Vikas Patil, Age: 23 Years, Occupation : Student, R/o. Tambepura, Sanenagar, Amalner, Tq. Amalner, Dist. Jalgaon.

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Umesh Omkar Malve, Age: 22 Years, Occupation: Student, R/O. Subhash Chowk, Ward No.2, Peth Budhwar, VTC Katol, Nagpur. 5. Rushikesh Rameshwar Nilkhan Age: 24 Years, Occupation: Student, R/o. Hatgaon, Tq. Murtijapur, District: Akola. … Petitioners Versus

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The Union of India, (Through Ministry of Home affairs, Govt. of India)

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Central Forensic Science Laboratory, HW4P+HXP Krishna Complex, 38/4, Mundhwa, Kharadi Road, Yashwant Nagar, Kharadi Road, Pune – 411 011.

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National Cyber Crime Reporting Portal, 5^th Floor, NDCC-II Building, Jaisingh Road, New Delhi – 110001.

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12450-25-WP (+3).odt

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{3}
4. Staff Selection Commission, Through its Chairman, Block No.12, CGO Complex, Lohi Road, New Delhi – 110003
5. Commandant, CISF Unit HP-BPCL, Mahulgaon, Chembur, Mumbai – 400074.	...Respondents
AND WRIT PETITION NO.7994 OF 2025
1. Darshan Gorakh Patil, Age: 24 Years, Occupation: Student, R/o. Shriram Samarth Colony, Tadepura, Tq. Jamner, District. Jalgaon.
2. Ganesh Lotan Patil, Age: 24 Years, Occupation : Student, R/o. Fapore Bk. Tq. Amalner, Dist. Jalgaon.
3. Vishal Bapu Surag Age: 24 Years, Occupation : Student, R/o. Ambodetal, Tq. and Dist. Dhule.	… Petitioners
Versus
1. The Union of India, (Through Ministry of Home affairs, Govt. of India)
2. Central Forensic Science Laboratory, HW4P+HXP Krishna Complex, 38/4, Mundhwa, Kharadi Road, Yashwant Nagar, Kharadi Road, Pune – 411 011.
3. National Cyber Crime Reporting Portal, 5^thFloor, NDCC-II Building, Jaisingh Road, New Delhi – 110001.

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12450-25-WP (+3).odt

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1. Staff Selection Commission, Through its Chairman, Block No.12, CGO Complex, Lohi Road, New Delhi – 110003. ...Respondents

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AND

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WRIT PETITION NO.7993 OF 2025

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Dinesh Nandlal Patil, Age: 24 Years, Occupation: Student, R/o. Dhangarwada, Post. Virwade, Tq. Chopda, Dist. Jalgaon. … Petitioner Versus

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The Union of India, (Through Ministry of Home affairs, Govt. of India)

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Central Forensic Science Laboratory, HW4P+HXP Krishna Complex, 38/4, Mundhwa, Kharadi Road, Yashwant Nagar, Kharadi Road, Pune – 411 011.

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National Cyber Crime Reporting Portal, 5^th Floor, NDCC-II Building, Jaisingh Road, New Delhi – 110001.

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Staff Selection Commission, Through its Chairman, Block No.12, CGO Complex, Lohi Road, New Delhi – 110003. ...Respondents

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Mr. Satej S. Jadhav, Advocate for Petitioners in all WPs

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Mr. R.B. Bagul, Senior Panel Counsel and Mr. N.T. Bhagat, Central Government Counsel for all respective respondents in respective WPs

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CORAM : SMT. VIBHA KANKANWADI AND HITEN S. VENEGAVKAR, JJ. DATED : 15 OCTOBER, 2025

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JUDGMENT [Per Hiten S. Venegavkar, J.] :-

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Rule . Rule made returnable forthwith. Heard finally with the consent of the learned counsels appearing for both the sides.

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The petitioners in the respective petitions have approached this Court under Article 226 of Constitution of India seeking directions to the respondents to declare their results for the recruitment to the post of Constable (GD) and Rifleman (GD) in the various departments such as Central Armed Police Forces (CAPFs), Secretariat Security Force (SSF), Assam Rifles (AR), Border Security Force (BSF), Central Industrial Security Force (CISF), Central Reserve Police Force (CRPF), Sashastra Seema Bal or Services Selection Board (SSB) and IndoTibetan Border Police (ITBP), pursuant to the advertisement No. 2411 of 2023, issued on 24^th November 2023. It is the case of the petitioners that they possessed all the requisite qualifications prescribed for the said post. The petitioners duly applied and were permitted to appear for the written examination and having cleared the same were also called for the physical efficiency test, physical standard tests and document verifications. During the document verification process, the biometric details of the petitioners were found to be not matching with those recorded earlier in the recruitment database. Despite such observation, the petitioners were permitted to appear for the medical examination which was duly conducted by the respondents. Even upon subsequent

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12450-25-WP (+3).odt

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biometric tests, the mismatch persisted. Consequently, the petitioners were initially declared unfit and were directed to undergo medical re-examination.

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The petitioners thereafter underwent medical re-examination and were declared fit and eligible for selection. The verification of documents and the medical examination process was thus completed. Notwithstanding their successful completion of all stages of the recruitment process, the respondents withheld the result of the petitioners solely on the ground of biometric mismatch, even though the final result for other candidates was published on 14^th December, 2024.

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According to the petitioners, the biometric mismatch is not a fault attributable to them. The forensic report regarding the verification of biometric data, forwarded by the respondents to the forensic department, is still awaited for a considerable time without any progress. The petitioners have therefore approached this court seeking directions to expedite the process of obtaining the forensic report and or

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to direct the respondents to publish their results so that they may participate in the forthcoming training programme likely to commence within a few weeks.

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The learned Advocate appearing for the respondents submitted that the results in relation to biometric mismatch are still awaited, and

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therefore, the results of the petitioners could not be declared till the receipt of the forensic report. During the course of the hearing, the petitioners’ Advocate also brought to the notice of this Court that similarly situated candidates have preferred a writ petition No.975 of 2025 and other companion matters before the Bombay High Court, Nagpur Bench and those petitioners were also appearing in the same examination and for the same position. Their results were also withheld only due to the reason of biometric mismatch. He relied upon paragraph 8, 9 and 10 which reads thus:

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“8. Having considered the rival submissions, it appears that it is a matter of record that the petitioners’ candidature was considered by the respondents, thereafter, the written examination conducted is also successfully cleared by the petitioners herein. Resultantly, the physical and document verification was carried out. However, but for Biometric mismatch which is conducted by the respondents themselves, which is according to us is not attributable to the petitioners herein, the petitioners have been otherwise declared successful. Therefore, in our considered view, the respondents are not justified in withholding the results since the recruitment process has commenced in the month of November 2023 and after lapse of substantial period, the respondents are not justified in withholding the results of the petitioners, to which petitioners are legitimately entitled for, in the wake of petitioners’ successfully clearing the written examination so also further act of medical re-examination conducted by the respondents. Therefore, we direct the respondents to declare the result of the petitioners within a period of four weeks from today.

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Needless to state that the candidature of the petitioners deserves to be considered on their respective merit and if the petitioners are otherwise qualified.

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The writ petitions are allowed. Rule is made absolute in the above terms with no order as to costs.”

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Upon making a query with the respondents advocate, whether the facts of the present petitions and the facts before the Nagpur bench in the above order are similar. He agreed and fairly submitted that all the petitioners therein are similarly situated to the one which is before us in the present petitions.

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In light of the order dated 30^th June 2025 passed by the division

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bench of the Bombay High Court, Nagpur bench in writ petitions No.975 of 2025, 976 of 2025 and 977 of 2025, this court finds that the facts and issues involved in the present petitions are identical and the ratio of the said judgment squarely applies to the present case.

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Accordingly, the present petitions are allowed in terms of paragraphs 8, 9 and 10, extracted above. The respondents are directed to declare the results of the petitioners within 4 weeks from the date of this order.

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Rule made absolute in above terms, no orders as to costs.

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[ HITEN S. VENEGAVKAR ] [ SMT. VIBHA KANKANWADI ] JUDGE JUDGE

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S P Rane

Procedural history

How this case reached the court

AI extract

Order under challenge
Withholding of the petitioners' results for the Constable (GD)/Rifleman (GD) recruitment solely on the ground of biometric mismatch, pending a forensic report, despite the petitioners' completion of all recruitment stages including medical re-examination.¶¶42
Respondent authorities (Union of India / Staff Selection Commission)
Prior proceeding
Recruitment advertised vide Advertisement No. 2411 of 2023, issued on 24 November 2023, for the post of Constable (GD) and Rifleman (GD) in CAPFs, SSF, Assam Rifles, BSF, CISF, CRPF, SSB and ITBP.¶¶39
Prior proceeding
Petitioners applied, were permitted to appear for the written examination, cleared it, and were called for the physical efficiency test, physical standard tests and document verification.¶¶39
Prior proceeding
During document verification, the petitioners' biometric details were found not to match the records in the recruitment database.¶¶39
Prior proceeding
Despite the mismatch observation, the petitioners were permitted to appear for the medical examination conducted by the respondents.¶¶39
Prior proceeding
The petitioners were initially declared unfit and directed to undergo medical re-examination.¶¶41
Prior proceeding
The petitioners underwent medical re-examination and were declared fit and eligible for selection.¶¶42
Prior proceeding
The final result for other candidates was published on 14 December 2024, while the petitioners' results remained withheld solely on the ground of biometric mismatch.¶¶42
Prior proceeding
The forensic report on verification of the biometric data, forwarded by the respondents to the forensic department, remained awaited without progress.¶¶43
Prior proceeding
Similarly situated candidates of the same examination and position preferred Writ Petition No.975 of 2025 and companion matters before the Bombay High Court, Nagpur Bench; their results were likewise withheld only due to biometric mismatch.¶¶48
Prior proceeding
The division bench of the Bombay High Court, Nagpur Bench allowed Writ Petitions Nos. 975, 976 and 977 of 2025 by order dated 30 June 2025, directing declaration of the results within four weeks.¶¶56
Prior proceeding
On a query from the Court, the respondents' advocate agreed and fairly submitted that the petitioners in the Nagpur Bench matters are similarly situated to the petitioners before this Court.¶¶54

Satish Khandu Patil and Others v. the Union of India through Ministry of Home Affairs and Others

Case brief

What is this about?

What did the court decide?

Satish Khandu Patil and Others v. the Union of India through Ministry of Home Affairs and Others

Case brief

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What the court decided

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