Priyanshu Raj Vs Union of India & Ors.

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$~65

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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% Date of Decision : 08.01.2026

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- W.P.(C) 18334/2025, CM APPL. 75914/2025, CM APPL. 79175/2025

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PRIYANSHU RAJ .....Petitioner

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Through: Mr. Moksh Arora, Mr. Manish Kumar Srivastava and Mr. Hardik Vashisht, Advs.

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versus

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UNION OF INDIA & ORS. .....Respondents Through: Mr. Jagdish Chandra Solanki, CGSC, Mr. Siddharth Bajaj and Ms. Maanya Saxena, Advs. for UOI/R-1 Mr. Ravinder Agarwal, Mr Manish Kumar Singh, Mr. Vasu Agarwal, Mr. Shekhar Vya and Ms. Neha Warrier, Advs for UPSC

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CORAM:

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HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

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MANMEET PRITAM SINGH ARORA, J. ( ORAL )

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The present writ petition has been filed under Article 226 and 227 of the Constitution of India for issuance of an appropriate writ, order or direction thereby setting aside the Physical Standard Test (‘PST’) rejection slip dated 17.11.2025 disqualifying Petitioner from appearing for Physical Efficiency Test (‘PET’) in Central Armed Police Forces (Assistant Commandants), Examination 2025 and declare the Petitioner eligible for PET by extending the benefit of relaxation to Petitioner as contemplated under Clause 2(d) of the Revised Guidelines for Recruitment Medical Examination in Central Armed Police Forces and Assam Rifles dated 20.05.2015 (as revised on

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Signature Not Verified

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W.P.(C) 18334/2025 Page 1 of 12

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Signed By:HEMANT PRATAP SINGH Signing Da te:1 6.01.2026 14:31

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31.05.2021)[‘Guidelines’].

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The relevant facts in brief as set out in the petition are as under:

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2.1 Petitioner is a person interested in the post of Assistant Commandant in Central Armed Police Forces 2025.

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2.2 The Respondent No. 1 is the Ministry of Home Affairs who published Rules for the examination process in Gazette of India dated 05.03.2025 as issued by Respondent No. 2/UPSC and invited applications. Respondent No. 3 is the offices of Directorate General, ITBP who had issued Admit card directing Petitioner to appear before Respondent No. 4 on 17.11.2025 for PST/PET. Respondent no. 4 issued the PST Rejection Slip dated 17.11.2025 to the Petitioner.

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2.3 Government of India, Ministry of Home Affairs, vide Office Memorandum bearing No. A.VI- 1/2014-Rectt (SSB) dated 20.05.2015 as revised vide MHA UO No. E- 32012/ADG(Med)/DME&RME/ DA-1/2020 (Part File)/1166 dated 31.05.2021, had approved the Guidelines for Recruitment Medical Examination in CAPFs & AR, for implementation.

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2.4 Respondent No.2 vide Examination Notice dated 05.03.2025 bearing no. 09/2025-CAPF (‘Notice’), invited applications from eligible candidates, for the post of Assistant Commandants in Central Armed Police Forces viz. Border Security Force, Central Reserve Police Force, Central Industrial Security Force, Indo-Tibetan Border Police and Sashastra Seema Bal. Said Notice prescribed various stages for the recruitment of the candidate(s) for the said post, such as (a) written examination, (b) Physical Standard Test (PST)/ Physical Efficiency Test (PET), (c) Interview/Personality Test and (d) Medical Standards Tests.

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2.5 Petitioner, on 03.08.2025, being eligible and satisfying the requisite

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Signature Not Verified

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qualifications prescribed in the said Notice applied for the said post under General Category. Admit card bearing Roll No. 0800642 was issued to Petitioner to appear for the written examination on 03.08.2025.

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2.6 Petitioner vide results dated 10.10.2025 was declared qualified in the Written Examination.

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2.7 Thereafter, Petitioner duly appeared before Respondent No. 4 for the PST on 17.11.2025 and was declared disqualified in the said test on the ground that the height of petitioner was “ Less In Height ” i.e., less than the standard height [165 cm], prescribed in the said Notice.

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2.8 Learned counsel for the Petitioner states that the Petitioner’s height is 164.6 cm as confirmed by virtue of General OPD Card cum Certificate dated 27.11.2025 as issued by one Dr. Arun Khatri, M.B.B.S M.D. (Internal Medicine), Sushila Hospital, Narela, Delhi.

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2.9 Being aggrieved by impugned PST rejection slip dated 17.11.2025, Petitioner filed the present writ petition.

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The Court vide order dated 03.12.2025 after recording its prima facie opinion in favour of the Petitioner to the effect that Petitioner would be entitled to the rounding of the height to 165 cm as stipulated at clause 2(d) of the Guidelines, observed that the impugned rejection slip dated 17.11.2025 is illegal. The petitioner was permitted to participate in the further rounds of selection, subject to outcome of the writ petition.

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3.1. In pursuance of the liberty granted, the Petitioner appeared for the Physical Efficiency Test on 23.12.2025 and has qualified the said test. The Petitioner is now scheduled to appear for interview/personality test and thereafter the medical standard test.

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Learned counsel for the Respondents states that at the stage of PST, the

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Signature Not Verified

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W.P.(C) 18334/2025 Page 3 of 12

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candidate must qualify the prescribed physical measurement for height, weight and chest as notified. The candidates who do not meet these requirements cannot be declared as qualified. Clause 2(d) of the Guidelines is relevant only during the Detailed Medical Examination (‘DME’) stage to be conducted after a candidate has cleared the PST. The rounding off for height is strictly for BMI¹ assessment and can only be done at the stage of DME and cannot be applied at the PST stage. Therefore, the candidate/Petitioner measuring 164.6 cm at the PST stage cannot claim to meet the 165 cm minimum height requirement by invoking Clause 2(d) of the Guidelines. The PST eligibility must be determined strictly on unaltered physical measurements without any rounding off or relaxation.

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4.1. He relies upon the clarification dated 19.11.2025 issued by office of ADG (Med), CAPFs, NSG & AR to submit that rounding off 0.5 cm height to the next higher centimetre is applicable only for assessment of BMI during the DME stage.

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He also relies upon the order dated 20.11.2025 of High Court of Madhya Pradesh in Writ Appeal No. 2932/2025 titled Union of India & Ors vs. Arun Kalmodiya , which held that object of relaxation of Clause 2(d) of the Guidelines for the purpose of DME stage and opined that a candidate whose height is measured at 169.6 cm cannot be treated as 170 cm by relaxing the minimum prescribed height.

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In reply learned counsel for the Petitioner has relied upon the judgments of High Court of Punjab and Haryana in Kuldeep v. Union of India and Ors.² dated 12.07.2019 , which was affirmed by the Division Bench in LPA

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1 Body Mass Index[‘BMI’]

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2 2019:PHHC:081181 at paragraphs 2 and 7

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1724/2019³ vide judgment dated 24.07.2024. Petitioner also relies on the judgments of High Court of Bombay in Sushant Bhausaheb Sarode v. Union of India⁴ and Aniket Sunil Jadhav v. Union of India⁵ as well as High Court of Calcutta in Anuj Bala v. Union of India and Ors.⁶ . He states that in the aforesaid judgments the High Court has interpreted the Clause 2(d) of the Guidelines in favour of the candidate/Petitioner and held that the benefit of rounding off has to be made applicable at the stage of PST.

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This Court has heard the learned counsel for the parties and perused the record.

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Vide Examination Notice dated 05.03.2025, Respondent No. 2 invited applications from eligible candidates for the post of Assistant Commandants in the Central Armed Police Forces. The said Notice at, Appendix V provided the ‘Physical Standards’ which were the minimum requirements for each candidate. The relevant extract of Appendix V reads as under:

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The reference to Appendix II(B) is a typographical error as it should be Appendix V(B).

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3 2024:PHHC:093548-DB

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4 2025 SCC Online Bom 3586 at paragraph 16 to 19

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5 2025 SCC Online Bom 3947 at paragraph 16 to 19

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6 2025 SCC Online Cal 7703 at paragraph 18 to 20

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Signature Not Verified

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W.P.(C) 18334/2025 Page 5 of 12

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Signed By:HEMANT PRATAP SINGH Signing Da te:1 6.01.2026 14:31

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The Petitioner appeared for PST on 17.11.2025, wherein he was disqualified on account of his height measurement recorded at 164.5 cm. The relevant portion of the individual record booklet of the PST filed by the Respondents at Annexure R-3A of the Respondent’s Documents is as under:

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The note appearing in brackets below 1(b) above is relevant and has been considered hereinafter during analysis.

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The Petitioner filed an appeal before the Respondent. In the appeal, upon remeasurement, it is undisputed that the Petitioner measures 164.6 cm. This is also borne out from the report of the Appellate Authority dated 17.11.2025 filed by Respondents on record as Annexure R-2. The relevant portion reads as under:

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Signature Not Verified Signed By:HEMANT PRATAP SINGH Signing Da te:1 6.01.2026 14:31

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W.P.(C) 18334/2025 Page 6 of 12

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Petitioner has relied upon Clause 2(d) of the General instructions for Recruitment Board issued by the Government of India, Ministry of Home Affairs on 20.05.2015 to contend that the said Guideline permits rounding off the height to the next higher centimetre and therefore the petitioner’s height which is 164.6 cm ought to be rounded off to 165 cm at the stage of PST. The said Guideline as relevant is extracted hereinbelow:

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‘“ 2. GENERAL INSTRUCTIONS FOR RECRUITMENT BOARD:

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d) Measurement of physical standards viz. height, weight, and chest is the responsibility of the PST Board (PST Board) for all categories of candidates i.e GOs, SOs and Ors. Medical Officers will not be part of PST board both for Male & Female candidates. Since presence of a female is required at the time of recording of physical standard (PST), a female non-medical staff may be associated with PST board. Recruiting medical officer need not record to physical measurements. Recruiting medical officer will mention physical standard in the medical examination form as recorded by the PST board. In borderline cases of overweight, BMI should also be considered to arrive at conclusion and variation of 5Kg +/- from the minimum/maximum limit may be accepted. Similarly, while measuring height fraction of cm less that 0.5 will be ignored and 0.5 cm & more will be rounded off to the next higher cm. Standard height weight chart is attached as Annexure I’

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[Emphasis Supplied]

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The Respondents have raised two submissions to oppose the contention of the Petitioner. First , it contends that rounding off permissible under Clause 2(d) of the Guidelines is confined to medical evaluation at the DME stage and cannot be applied at the PST stage. At the PST stage eligibility is to be determined strictly on the unaltered physical measurements provided in the Notice inviting applications for Recruitment, without any rounding off or relaxation. Second , it contends that the rounding off the height to the next higher centimetre is applicable only for the purpose of assessment of the BMI for weight during the DME stage.

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This Court is unable to accept the contentions of the Respondents that

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the relaxation contemplated under Clause 2(d) of the Guidelines can only be permitted at the stage of DME and not at the stage of PST. The submission of the Respondents if accepted would negate the purpose of extending the said relaxation to a candidate. As noted above, Appendix V to the Notice dated 05.03.2025 provides absolute physical standards for both height and weight; it also refers to a height weight chart as Appendix-V (B)⁷ and records that the weight of the candidate appearing for PST should be as per the said heightweight chart. Even as per the Respondents, Clause 2(d) of the Guidelines is intended to relax the said weight measurement in vis-à-vis an overweight candidate. Therefore, if a candidate is overweight as per the height weight chart provided in Appendix-V(B) and benefit of Clause 2(d) of the Guideline with respect to weight relaxation is to be extended to that candidate it would have to be done at the PST stage or else an overweight candidate would be excluded from the recruitment process at the PST stage as disqualified and not reach the DME stage. The benefit of the relaxation of the Guidelines, even for height as per Clause 2(d) would therefore have to be extended to the candidate at PST stage so that he can reach the DME stage, where it would be re-verified by the Medical Officer and disqualification if any on the grounds of physical standards would takes place at the DME stage. This also becomes evident from the note appearing in the individual record booklet under 1(b) extracted above. Thus, the benefit of 2(d) has to be extended at the PST stage and the same shall remain subject to the DME.

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This Court is unable to accept the next contention of the Respondents that the relaxation of 0.5 cm and more for height contemplated in Clause 2(d) is solely for the purpose of assessment of BMI in case of an overweight

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7 Page 23 of the Notice dated 05.03.2025 in the petition.

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candidate during the DME. The said submission is not borne out on a plain reading of the relevant portion of the Guidelines extracted above, which in the considered opinion of the Court ex-facie appears to be independent and not linked to measurement of BMI for weight.

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In addition, the Manual of Medical Examination and Medical Standards for various entries into Army, TRG Academies and MIL Schools, which is an appendix to DGMS (Army) letter 76054/policy/DGMS-5A dated 16.07.2019 has come to our attention while hearing proceedings in a different writ petition. The said Manual at Section 2 provides for Anthropometric Standards for measurement of height, weight and chest circumference of the candidates. The method of recording the measurement of the height is set out at paragraph 48 (a), which reads as under:

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Method of Examination.

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The three basic measurements which are required to be carried out for all candidates are height, weight and chest circumference. In certain instances two more measurements, namely waist circumference and hip circumference, may be required for further assessment. In order to standardize these measurements, the recruiting equipment (weighing scales, anthropometric rods and tape measures) must be procured centrally and provided to all establishments. The method of recording these measurements is given below;-

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(a) Height . The measurement of height requires a vertical board with an attached metric rule and a horizontal headboard that can be brought into contact with the uppermost point of the head. The individual to be measured should be bare foot and wearing little clothing so that the positioning of the body can be seen. He/she should stand on a flat surface, with weight distributed evenly on both feet, knees straight, heels together and the

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head positioned so that the line of vision is perpendicular to the body. The arms should hang freely by the side and the head, back, buttocks and heels are in contact with the vertical board. The Individual is asked to inhale deeply and maintain a fully erect position. The movable headboard is brought onto the topmost point on the head with sufficient pressure to compress the hair. The height is recorded to the nearest cm.

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The said paragraph 48 (a) as well notes that the height of the candidate is to be recorded to the nearest centimeter (cm).

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This is the standard prescribed by DGMS in the Manual for the medical teams, who have to undertake the examination of the candidates for these measurements. The said paragraph 48 (a) also supports the contentions canvassed by the Petitioner and applying the said method as well the Petitioner was entitled to rounding off to 165 cm at the stage of PST.

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We thus, find ourselves in agreement with the opinions expressed by the High Court of Punjab and Haryana, High Court of Bombay and High Court of Calcutta.

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Insofar as the judgment of the High Court of Madhya Pradesh on which reliance has been placed by the counsel for the respondents is concerned, the High Court of Madhya Pradesh has come to a conclusion that there is no concession or relaxation in respect of physical standards viz. height, weight and chest, which is fixed at the time of Physical Standard Test (PST) at paragraph 14 of the said judgment, which reads as under:-

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“14. The aforesaid clause 2(d) is clear as "noon day" that the relaxation which is required has to be considered at the stage of Detailed Medical Examination (DME). There is no concession or relaxation in respect of the physical standards viz

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height, weight and chest which is fixed at the time of physical standard Test (PST). The language is plain and clear that at the time of Detailed Medical Examination in borderline cases of overweight, BMI should also be considered before arriving at a conclusion and variation of 5Kg +/- from the minimum/maximum limit may be accepted. Similarly, while measuring height fraction of cm less than 0.5 will ignored and 0.5 cm and more will be rounded off to the next higher cm standard height and weight. Thus, a person having less than prescribed 170 cm of height can never be cleared by physical standard test board. There cannot be relaxation at that time. Only at the stage of DME and at the time of BMI, there may be variation of 5kg +/- from the minimum/maximum limit and similarly if there is a fraction of cm less than 0.5 or 0.5 more than the same can be rounded of to the next higher cm standard height/weight. The same can be very well understood by demonstration that if a person is having 171 cm(more than standard height 170 cm) qualifies PST but at the time of BMI there is variation of either in the weight(+/- 5 kg) or in the height (+/- 0.5 cm), the same has to be rounded off because when the process of BMI is conducted, there may be varience in respect of weight and height.”

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The Court in the aforesaid judgment has also reached to its conclusion based on an example, wherein the height of the candidate is taken as 171 cm, that is, more than 170 cm, the applicable height. However, it has not considered the converse of the example given. In other words, it may so happen that in a given case, the person’s height is 169.6 cm though less than 170 cms but more than 169.5 cm, the Clause 2(d) of the Guidelines contemplate that at the time of BMI, if there is a variation in the height +/- 0.5 cm, the same can be rounded off. It means at the time of BMI, the height of 169.6 cm can be rounded off by 0.5 cm, which means, on rounding off the

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height shall be 170 cm, meeting the eligibility.

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It therefore follows in a given case, at the time of PST, where the height of a candidate is 169.5 cm or more but less than 170 cm, the candidature of such a person cannot be cancelled. It is not to say, if the height of a candidate/person is less than 169.5 cm in PST, his candidature cannot be cancelled. In that sense, the judgment is distinguishable.

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This Court, therefore finds that the Petitioner herein was entitled to seek benefit of Clause 2(d) of the Guidelines vis-à-vis height at the stage of PST and accordingly the petition is allowed and the PST rejection slip dated 17.11.2025 is hereby quashed.

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As noted above, the Petitioner has already cleared the PET on 23.12.2025 and will therefore be eligible to proceed to the next stage of the recruitment process. The Respondents are directed to act accordingly.

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The aforesaid writ petition is allowed and pending applications, if any, stands disposed of.

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MANMEET PRITAM SINGH ARORA, J

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V. KAMESWAR RAO, J

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JANUARY 8, 2026/ msh/IB

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Signed By:HEMANT PRATAP SINGH Signing Da te:1 6.01.2026 14:31

Priyanshu Raj v. Union of India & Ors.

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Priyanshu Raj v. Union of India & Ors.

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