Allowed¶8

Dinesh Nandlal Patil v. the Union of Idnia through Ministry of Home Affairs and Others

Bombay HC15 Oct 2025WP/7993/2025

Case brief

AI extract

What is this about?

Aurangabad Bench, Bombay High Court; W.P. Nos. 12450, 3579, 7994 and 7993 of 2025; Article 226; Constable (GD) and Rifleman (GD) recruitment under advertisement No. 2411 of 2023 (CAPFs, SSF, Assam Rifles, BSF, CISF, CRPF, SSB, ITBP); biometric mismatch at document verification; results withheld pending forensic report; other candidates' final result published 14th December 2024; order dated 30th June 2025 of Bombay High Court Nagpur Bench in W.P. Nos. 975, 976 and 977 of 2025 followed; results to be declared within four weeks; Rule absolute, no costs.

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 orders as to costs. ¶8

Dinesh Nandlal Patil Vs the Union of Idnia through… — Writ and Judicial Review | Bombay HC (2025)

What the court decided

AI extract

Outcome

¶8

Issue for consideration

Whether the petitioners' results for the post of Constable (GD)/Rifleman (GD), withheld solely on account of biometric mismatch after they had completed all stages of the recruitment process including medical re-examination, ought to be declared. +1 more

¶3

Court's answer

The present petitions are allowed in terms of paragraphs 8, 9 and 10 of the Nagpur Bench order extracted in the judgment; the respondents are directed to declare the results of the petitioners within four weeks from the date of the order.

¶8

Ratio / Principle

The facts and issues in the present petitions are identical to those before the Bombay High Court, Nagpur Bench, and the ratio of its order dated 30th June 2025 in Writ Petition Nos. 975, 976 and 977 of 2025 squarely applies to the present case.

¶7

Detailed headnote1 paragraphs

Recruitment – Constable (GD)/Rifleman (GD) pursuant to advertisement No. 2411 of 2023 (issued 24th November 2023) for CAPFs, SSF, Assam Rifles, BSF, CISF, CRPF, SSB and ITBP – petitioners cleared written examination and were called for physical efficiency test, physical standard tests and document verification – biometric mismatch noticed during document verification and persisting on subsequent tests – petitioners initially declared unfit but declared fit on medical re-examination – results withheld solely on ground of biometric mismatch pending forensic report, while final result of other candidates published on 14th December 2024 – facts and issues identical to order dated 30th June 2025 of Bombay High Court, Nagpur Bench in W.P. Nos. 975, 976 and 977 of 2025, similarity conceded by respondents' counsel – ratio of that order held to squarely apply – petitions allowed in terms of paragraphs 8, 9 and 10 thereof – respondents directed to declare petitioners' results within 4 weeks – Rule made absolute, no costs.

¶1

2025:BHC-AUG:30071-DB

¶2

12450-25-WP (+3).odt

¶3

{1}

¶4

IN THE HIGH COURT OF JUDICATURE AT BOMBAY BENCH AT AURANGABAD

¶5

WRIT PETITION NO.12450 OF 2025

¶6

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

¶7

Versus

¶8

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

¶9

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

¶10

12450-25-WP (+3).odt

¶11

{2}

¶12

WRIT PETITION NO.3579 OF 2025

¶13

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

¶14

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

¶15

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

¶16

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

¶17

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

¶18

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

¶19

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

¶20

12450-25-WP (+3).odt

¶21

{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.

¶22

12450-25-WP (+3).odt

¶23

¶24

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

¶25

AND

¶26

WRIT PETITION NO.7993 OF 2025

¶27

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

¶28

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

¶29

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

¶30

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

¶31

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

¶32

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

¶33

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

¶34

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

¶35

12450-25-WP (+3).odt

¶36

{5}

¶37

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

¶38

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

¶39

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

¶40

12450-25-WP (+3).odt

¶41

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

¶42

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.

¶43

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

¶44

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.

¶45

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

¶46

12450-25-WP (+3).odt

¶47

{7}

¶48

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:

¶49

“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.

¶50

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

¶51

12450-25-WP (+3).odt

¶52

{8}

¶53

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

¶54

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.

¶55

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

¶56

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.

¶57

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.

¶58

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

¶59

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

¶60

S P Rane

Procedural history

How this case reached the court

AI extract

Order under challenge
Withholding of the petitioners' results for the post of Constable (GD)/Rifleman (GD) solely on the ground of biometric mismatch pending the forensic report, even though the petitioners had completed all stages of recruitment including medical re-examination and the final result for other candidates was published on 14th December, 2024.¶3
Union of India / Staff Selection Commission / Central Forensic Science Laboratory (respondents)
Prior proceeding
Petitioners applied pursuant to advertisement No. 2411 of 2023 (issued 24th November 2023) for recruitment to the post of Constable (GD) and Rifleman (GD) in CAPFs, SSF, AR, BSF, CISF, CRPF, SSB and ITBP.¶2
Prior proceeding
Petitioners cleared the written examination and were called for physical efficiency test, physical standard tests and document verifications.¶2
Prior proceeding
During document verification, petitioners' biometric details did not match those recorded earlier in the recruitment database; the mismatch persisted on subsequent biometric tests.¶2
Prior proceeding
Petitioners were initially declared unfit and directed to undergo medical re-examination.¶2
Prior proceeding
After medical re-examination the petitioners were declared fit and eligible for selection.¶3
Prior proceeding
Results of the petitioners were withheld solely on the ground of biometric mismatch although the final result for other candidates was published on 14th December, 2024.¶3
Prior proceeding
Forensic report on verification of biometric data awaited for a considerable time without progress; petitioners sought directions to expedite it or publish results.¶4
Prior proceeding
Similarly situated candidates had approached the Bombay High Court, Nagpur Bench in Writ Petition No. 975 of 2025 and companion matters arising from the same examination and post, with results likewise withheld for biometric mismatch; the Nagpur Bench allowed those petitions by order dated 30th June 2025 directing declaration of results within four weeks.¶7
Prior proceeding
Respondents' counsel, upon query, agreed and fairly submitted that the Nagpur Bench petitioners were similarly situated to the present petitioners.¶6

Dinesh Nandlal Patil v. the Union of Idnia through Ministry of Home Affairs and Others

Case brief

What is this about?

What did the court decide?

Dinesh Nandlal Patil v. the Union of Idnia through Ministry of Home Affairs and Others

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Cases cited

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Ravindra Sadhu Kamble and Others Vs the State of Maharashtra through Secretary and Others

Babu Vithoba Jagale and Others Vs the State of Maharashtra through Collector and Others

Maharashtra Kamgar Karmachari Thr Its Mail Majur Unit Secretary Vs the State of Maharashtra and Another

Dagdu Omkar Narwane and Others vs the State of Maharashtra through Its Principal Secretary and Another

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

Darshan Gorakh Patil and Others Vs the Union of India through Ministry of Home Affairs and Others