Allowed

Ratul Talukdar v. the Union of India and Others

Gauhati HC1 Dec 2025WP(C)/5906/2025

Case brief

AI extract

What is this about?

Candidates for Constable (GD) recruitment in CAPFs and Assam Rifles were disqualified in the Physical Standard Test for heights of 164.5 to 164.8 cm against the 165 cm requirement. The Court held Clause 2(d) of the Office Memorandum dated 20.05.2015 mandates rounding off fractions of 0.5 cm or more at the PST stage itself, set aside the disqualification orders, declared the petitioners eligible fo

What did the court decide?

Disqualification orders set aside; petitioners' heights rounded off to 165 cm per Clause 2(d) OM dated 20.05.2015 and declared eligible for Detailed Medical Examination.

Ratul Talukdar Vs the Union of India and Others — Service and Employment | Gauhati HC (2025)

Page No.# 1/16

GAHC010245642025

2025:GAU-AS:16537

THE GAUHATI HIGH COURT (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH)

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Case No. : WP(C)/6436/2025

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ARUP RAY

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S/O SHRI JATIN RAY, VILL- NO.2 DAKHIN MAKARA, PO-SILBARI ABADIPARA, PS BIJNI,DISTRICT CHIRANG, ASSAM PIN783393

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2: PRABHASH SUTRADHAR Vill JANIA P.O JANIA District BARPETA P.SBARPETA-781314

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3: KAYAM ALI

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S/O DORAG ALI Vill NOWAGAON P.O NOWAGAON District BONGAIGAON 783392

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VERSUS

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THE UNION OF INDIA AND OTHRS

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REPRESENTED BY THE COMMISSIONER AND SECRETARY TO GOVT. OF INDIA, MINISTRY OF HOME AFFAIRS, NEW DELHI-110001.

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2:THE STAFF SELECTION COMMISSION . REPRESENTED BY THE CHAIRMAN/ SECRETARY STAFF SELECTION COMMISSION BLOCK-12 CGO COMPLEX LODHI ROAD NEW DELHI-110003.

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3:THE REGIONAL DIRECTOR STAFF SELECTION COMMISSION RUKMINI NAGAR P.O- ASSAM SACHIVALAYA

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Page No.# 2/16

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GUWAHATI-06.

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4:THE DIRECTOR GENERAL

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CRPF RECRUITMENT BRANCH EAST BLOCK 7 LEVEL 4 SECTOR R.K PURAM

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NEW DELHI-110066.

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5:APPELLATE AUTHORITY

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REPRESENTATED BY OFFICER IN CHARGE CUM SUPERVISORE/APPELLATE AUTHORITY PST/PET BOARD RECRUITMENT OF CT/GD 2025 GC CRPF GUWAHAT

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Advocate for the Petitioner : MR. S. K. CHAKMA, MR N ALI,MR. D DEKA

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Advocate for the Respondent : DY.S.G.I.,

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Linked Case : WP(C)/5906/2025

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RATUL TALUKDAR S/O LT KUMUD TALUKDAR R/O VILL BHOTANTA MAHITARA P O BHOTANTA MAHITARA DIST BAJALI ASSAM 781328

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VERSUS

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THE UNION OF INDIA AND OTHERS REPRESENTED BY THE COMMISSIONER AND SECRETARY TO GOVT OF INDIA

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MINISTRY OF HOME AFFAIRS NEW DELHI 110001

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2:THE STAFF SELECTION COMMISSION SSC REPRESENTED BY THE CHAIRMAN /SECRETARY STAFF SELECTION COMMOSION

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BLOCK 12 CGO COMPLEX LODHI ROAD NEW DELHI 110003

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3:3THE REGIONAL DIRECTOR NER STAFF SELECTION COMMISSION RUKMINI NAGAR P.O- ASSAM SACHIVALAYA GUWAHATI-06.

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Page No.# 3/16

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4:THE DIRECTOR GENERAL CRPF RECRUITMENT BRANCH EAST BLOCK 7 LEVEL 4 SECTOR R.K PURAM NEW DELHI-110066.

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5:PRESIDING OFFICER PS/PET BOARD . RECRUITMENT OF CT/GD-2025 GC CRPF GUWAHATI- 781023. 6:PRESIDING OFFICER PST/PET BOARD ARTC S SHOKUVI DIMAPUR CENTER. -----------Advocate for : MR. D DEKA Advocate for : DY.S.G.I. appearing for THE UNION OF INDIA AND OTHERS

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Linked Case : WP(C)/6441/2025

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NARESH GOWALA S/O LAKHMAN GOWALA R/O VILL NO 1 KALAIGAON PO AND PS KALAIGAON DIST UDALGURI ASSAM PIN 784525 ROLL NO 5105065296

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VERSUS

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THE UNION OF INDIA AND 4 ORS. REPRESENTED BY THE SECRETARY OF THE MINISTRY OF HOME AFFAIRS GOVT OF INDIA NEW DELHI-1

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2:THE STAFF SELECTION COMMISSION

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REPRESENTED BY THE CHAIRMAN BLOCK NO 12 CGO COMPLEX LODHI ROAD NEW DELHI 03

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3:THE REGIONAL DIRECTOR STAFF SELECTION COMMISSION GUWAHATI ASSAM

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Page No.# 4/16

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HOUSE FED COMPLEX DISPUR GHY 6

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4:THE DIRECTOR GENERAL

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CENTRAL RESERVE POLICE FORCE RECRUITMENT EAST BLOCK 07 LEVEL 4 SECTOR 01 RK PURAM NEW DELHI 66

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5:THE DEPUTY INSPECTOR GENERAL OF POLICE

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(DIGP) CRPF CUM APPELLATE AUTHORITY GROUP CENTRE AMERIGOG GUWAHATI - 23 -----------Advocate for : MD H R AHMED Advocate for : DY.S.G.I. appearing for THE UNION OF INDIA AND 4 ORS.

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Linked Case : WP(C)/6293/2025

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UTTAM BASFOR S/O SHYAMNARAYAN BASFOR RO VILLAGE CHARGOLA TE PO LILACHILA PS RATABARI DIST SRIBHUMI ASSAM PIN NO 788734 ROLL NO 5111000355

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VERSUS

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THE UNION OF INDIA AND ORS REPRESENTED BY THE SECRETARY OF THE MINISTRY OF HOME AFFAIRS GOVT OF INDIA NEW DELHI 1

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2:THE STAFF SELECTION COMMISSION REPRESENTED BY THE CHAIRMAN

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Page No.# 5/16

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BLOCK NO 12 CGO COMPLEX LODHI ROAD NEW DELHI 03 3:THE REGIONAL DIRECTOR STAFF SELECTION COMMISSION GUWAHATI ASSAM HOUSE FED COMPLEX DISPUR GHY 6 4:THE DIRECTOR GENERAL CENTRAL RESERVE POLICE FORCE RECRUITMENT EAST BLOCK 07 LEVEL 4 SECTOR 01 RK PURAM NEW DELHI 66 5:THE DIRECTOR GENERAL ASSAM RIFLES NONGRIMMAW LAITUMUKHRAH GORALINE SHILLONG MEGHALAYA 11 6:THE APPELLATE AUTHORITY CT GD RECRUITMENT EXAMINATION 2025 ASSAM RIFLES TRAINING CENTRE SUKHOVI DIMAPUR NAGALAND 787115 -----------Advocate for : MD H R AHMED Advocate for : DY.S.G.I. appearing for THE UNION OF INDIA AND ORS

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Linked Case : WP(C)/5865/2025

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NIRAB PRATIM MEDHI AND ANR S/O JAYANTA MEDHI VILL- MATHARBORI

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RAMJUNGATI DIST NAGAON ASSAM PIN-782103 2: TINKU CHETRY S/O CHANDRABIR CHETRY CHARIPHUKHURI RAMGACHAKUA SONITPUR ASSAM PIN-784182 VERSUS THE UNION OF INDIA AND 5 ORS REPRESENTED BY THE COMMISSIONER AND SECRETARY TO GOVERNMENT OF INDIA MINISTRY OF HOME AFFAIRS NEW DELHI-110001

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2:THE STAFF SELECTION COMMISSION (SSC) REPRESENTED BY THE CHAIRMAN/ SECRETARY STAFF SELECTION COMMISSION BLOCK 12 CGO COMPLEX LODHI ROAD NEW DELHI-110003

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3:THE REGIONAL DIRECTOR (NER) STAFF SELECTION COMMISSION RUKMINI NAGAR P.O ASSAM SACHIVALAYA GUWAHATI-06.

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4:THE DIRECTOR GENERAL CRPF (RECRUITMENT BRANCH) EAST BLOCK 7 LEVEL 4 SECTOR 1 R.K PURAM NEW DELHI-110066.

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5:PRESIDING OFFICER- PST/PET BOARD RECRUITMENT OF CT/GD-2025 GC CRPF GUWAHATI- 781023. 6:PRESIDING OFFICER-PST/PET BOARD

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ARTC AND S (SHOKUVI) DIMAPUR CENTER.

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-----------Advocate for : MR. D DEKA Advocate for : DY.S.G.I. appearing for THE UNION OF INDIA AND 5 ORS

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:::BEFORE:::

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HON’BLE MR. JUSTICE KARDAK ETE

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Date on which judgment is reserved : N/A Date of pronouncement of judgment : 02.12.2025 Whether the pronouncement is of the operative of the judgment? : No

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Whether the full judgment has been pronounced? : Yes

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JUDGMENT & ORDER (ORAL)

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Heard Mr. P. N. Goswami, learned counsel for the petitioners in WP(C) No. 6436/2025, WP(C) No. 5865/2025 & WP(C) No. 5906/2025; and Mr. H. R. Ahmed, learned counsel for the petitioner in WP(C) No. 6293/2025 & WP(C) No. 6441/2025. Also heard Mr. S. S. Roy and Ms. S. Baruah, learned Central Government Counsels for the respondents.

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2. Challenge made in these writ petitions is to the rejection orders dated 29.08.2025, 30.08.2025, 23.09.2025, 27.10.2025, 29.10.2025, whereby the respondent authorities have disqualified the candidatures of the petitioners in

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the Physical Standard Test (PST) being below 165 cm required for the candidates belonging to the State of Assam, pursuant to the advertisement dated 05.09.2024, issued by the Staff Selection Commission for recruitment to the post to Constable (General Duty) in Central Armed Police Force (CAPFs), SSE, Rifleman (GD) in Assam Rifles and Sepoy in Narcotics Control Bureau. The petitioners have prayed for a direction to allow them to participate in the subsequent stages of the recruitment process by treating them as qualified with regards to the height by rounding off fraction of centimeter in the light of the Office Memorandum dated 20.05.2015, particularly Clause 2(d).

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3. Having considered that the issue involved in these writ petitions is similar on facts and law, same are taken up analogously and disposed of by this common judgment and order.

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4. The brief fact of the case is that pursuant to an advertisement dated 05.09.2024, issued by the Staff Selection Commission, for filling up of 39481 posts of Constable (General Duty) in Central Armed Police Force (CAPFs), SSE, Rifleman (GD) in Assam Rifles and Sepoy in Narcotics Control Bureau, the petitioners have applied for the post as per their respective order of preference. The said selection process consisted of Computer Based Examination (CBE), Physical Efficiency Test (PET), Physical Standard Test (PST) and Medical Examination. The petitioners have successfully cleared the CBE, PET and thereafter participated in the PST, wherein they were disqualified on the ground that their height fell short of the prescribed requirement of 165 cm, as reflected in the rejection orders dated 29.08.2025, 30.08.2025, 23.09.2025, 27.10.2025 and 29.10.2025. It is the case of the petitioners that when they participated in the earlier PST rally conducted by the respondent authorities, they were found qualified having been measured at 165 CMS or above; however, in the present

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PST conducted pursuant to the advertisement dated 05.09.2024, their heights were recorded as below 165 cm, as shown below:

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Measured/rejected Short of height
Sl
height (In CMS)
Name
No.
(In CMS)
WP(C) No. 6436/2025
1. Arup Ray 164.6 0.4
2. Prabhash Sutradhar 164.5 0.5
3. Kayum Ali 164.7 0.3
WP(C) No. 5865/2025
4. Nirab Pratim Medhi 164.7 0.3
5. Tinku Chetry 164.6 0.4
WP(C) No. 5906/2025
6. Ratul Talukdar 164.8 0.2
WP(C) No. 6293/2025
7. Uttam Basfor 164.5 0.5

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Page No.# 10/16

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WP(C) No. 6441/2025

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8. Naresh Gowala	164.7	0.3

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5. The petitioners contend that as per Clause 2(d) of the Office Memorandum dated 20.05.2015, while measuring height, fraction of cm less than 0.5 will be ignored and 0.5 cm & more will be rounded off to the next higher cm. However, the respondents/PST Board, in most illegal and arbitrary manner, have rejected the candidature of the petitioners in contravention of the said Clause 2(d) of the Office Memorandum dated 20.05.2015, despite they being qualified having requisite height of above 164.5 cm, which ought to have been rounded off to 165 cm. Hence, these writ petitions.

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6. Mr. P. N. Goswami and Mr. H. R. Ahmed, learned counsel for the petitioners, while referring to the Office Memorandum dated 20.05.2015, which lays down the general instructions for Recruitment Board, particularly Clause 2(d), submits that while measuring height, any fraction of centimetre less than 0.5 cm is to be ignored and 0.5 cm or more is to be rounded off to the next higher centimetre. The petitioners’ heights were recorded as 164.5 cm, 164.6 cm, 164.7 cm, and 164.8 cm, but the respondents, in disregard of the aforesaid guidelines, failed to round off 0.5 cm and above to the next higher centimetre. As a result, the petitioners have been deprived of their right to participate in the further stages of the recruitment process.

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7. Mr. P. N. Goswami, learned counsel for the petitioners, while relying on the judgment of Hon’ble Calcutta High Court dated 12.09.2025, passed in a batch of

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writ petitions, submits that the Calcutta High Court has held that if the benefit of rounding off height is not accorded at the stage of Physical Standard Test, the candidate is precluded from qualifying to proceed to the subsequent stage of Detailed Medical Examination. Consequently, the relaxation provided in the guideline becomes illusory, as only those candidates who have already met the height of 170 cm cut-off are eligible to appear for Detail Medical Examination. The Medical Board would be, therefore, unable to apply the said relaxation as the candidate is not presented before them. Any benefit conferred by the guidelines must be interpreted in a manner that prevents it from being rendered nugatory. If the advantage of rounding off is not applied at the initial stage of height measurement, it becomes ineffective at the subsequent stage. Based on such finding, the Calcutta High Court directed that the candidates whose heights have been recorded in the Physical Standard Test as 169.05 cm and above but below 170 cm be declared eligible for the Detailed Medical Examination.

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8. He submits that the aforesaid cases arose out of the same advertisement dated 05.09.2024 in respect of the State of West Bengal where the prescribed cut off height was provided at 170 cm and the petitioner in those cases, having measured 169.05 cm and above but below 170 cm, have been declared eligible taking into account of Clause 2(d) of the Office Memorandum dated 20.05.2015. He submits that in the present case, the petitioners having been measured the height of 164.5 and above and since the minimum height requirement for the State of Assam is 165 cm, the rejection of their candidature without applying Clause 2(d) of the Office Memorandum dated 20.05.2015 is arbitrary and illegal. Therefore, he prays that the respondent authorities be directed to round off the fraction of 0.5 cm and above to 165 cm and thereby declare the petitioners to be eligible to participate in the further stages of the recruitment process,

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particularly the Detailed Medical Examination.

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9. Mr. S. S. Roy and Ms. S. Baruah, learned Central Government Counsels for the respondents, submit that the benefit provided in Clause 2(d) of the Office Memorandum dated 20.05.2015 is to be conferred only at the stage of Detailed Medical Examination and not during the Physical Standard Test. They have submitted that a bare reading of Clause 2(d) makes it explicitly clear that the relaxation is confined exclusively to the medical examination stage. It is further submitted that the benefit under Clause 2(d) may be extended only in cases where a candidate is found to be overweight and it is the Medical Board alone that is empowered to accord such benefit. Therefore, according to the learned counsels, since the petitioners’ heights have been measured by the PST Board as 164.5 cm, 164.6 cm, 164.7 cm, and 164.8 cm respectively and the minimum required height is 165 cm, they have been rightly disqualified at the PST stage and consequently denied progression to the Detailed Medical Examination.

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10. I have considered the submissions of learned counsel for the parties and also perused the materials available on record.

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11. The petitioners, who have applied for the posts of Constable (General Duty) in Border Security Force (BSF), Central Industrial Security Force (CISF), Central Reserve Police Force (CRPF), Indo Tibetan Border Police Force (ITBP), Sashstra Seema Bal (SSB), Secretariat Security Force (SSF), Narcotics Control Bureau (NCB), Rifleman (GD) in Assam Rifles pursuant to the advertisement dated 05.09.2024, issued by the Staff Selection Commission, are admittedly measured their heights as 164.5 cm, 164.6 cm, 164.7 cm & 164.8 cm, respectively, by the PST Board. As per the advertisement dated 05.09.2024, the required minimum height is 165 cm for male candidates belonging to the State of Himachal Pradesh, Jammu & Kashmir, Ladakh and Assam. It is not disputed

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that the petitioners are the candidates belonging to State of Assam.

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12. The disqualification of the petitioners by the respondent authorities at the stage of the Physical Standard Test appears to have been made on the ground that their measured heights fell below 165 cm, which according to the petitioner is erroneous inasmuch as the relaxation provided in Clause 2(d) of Office Memorandum dated 20.05.2015 has not been applied while assessing the height.

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13. The Office Memorandum dated 20.05.2015 has been issued by the Government of India, Ministry of Home Affairs (Pers.II Desk) by way of revised uniform guidelines for recruitment medical examination for recruitment of Gazetted Officers and Non Gazetted Officers in the Central Armed Police Forces and Assam Rifles. For better appreciation, Clause 2(d) of the said Office Memorandum dated 20.05.2015 is extracted herein under:

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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 Physical Standard Test 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 at ANNEXURE-I.”

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14. A bare reading of the above Clause clearly shows that while measuring height, any fraction of a centimetre less than 0.5 is to be ignored and any

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fraction of 0.5 cm or more is to be rounded off to the next higher centimetre. Thus, the fraction of 0.5 cm and above are required to be rounded off to the next higher centimetre. In the present case, as noted above, the height of the petitioners have been measured at 164.5 cm, 164.6 cm, 164.7 cm & 164.8 cm, respectively, which clearly reflects that they are having the height of 164.5 to 164.8, the fractions of more than 0.5 cm and above, if rounded off, would be 165 cm and the requirement of the height is provided at 165 cm. Thus, if the relaxation provided at Clause 2(d) of Office Memorandum dated 20.05.2015 has been applied at the time of measurement of height, the petitioners appear to have been wrongly disqualified on the ground of their non-fulfilment of the height cut off of 165 cm.

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15. It is taken note that at the stage of Physical Standard Test, the Medical Examination Board has no role whatsoever. In fact, the presence of Medical Officer during the physical measurement of candidate is explicitly prohibited. The relaxation at Clause 2(d) of Office Memorandum dated 20.05.2015 provides that the rounding off in respect of both the height and weight applies at the stage of Physical Standard Test by the PST Board only as it provides that while measuring height, any fraction of centimetre less than 0.5 cm shall be ignored and any fraction of 0.5 cm and above shall be rounded off to the next higher centimetre. It also reflects that in borderline cases of overweight, Body Mass Index (BMI) should be considered to arrive at conclusion and variation of +5 Kg from the prescribed minimum/maximum limits may be accepted. It must be therefore understood that a standard BMI has not been prescribed in the recruitment rules themselves by applying the well-known height-weight formula. The BMI has been prescribed in the guideline where height and proportionate weight are specified. Therefore, the BMI of the candidate must be assessed in

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the light of format provided in Clause 2(d) of the Office Memorandum dated 20.05.2015.

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16. As observed by the Hon’ble Calcutta High Court in the above referred case, if the respondents’ argument is accepted that only the Medical Board can confer the benefit of relaxation under Clause 2(d), then the benefit of Clause 2(d) with regard to the height becomes illusory and redundant. If the candidates with height of 164.5 cm and above are excluded at the initial stage, there would be no opportunity for the Medical Examination Board to grant height relaxation at the stage of Detailed Medical Examination (DME). If the benefit of rounding off height is not accorded at the stage of Physical Standard Test, the candidate would be precluded from qualifying to proceed to the subsequent stage of the Detailed Medical Examination. Consequently, the relaxation provided in the guideline would become illusory and redundant as only those candidates who have already met the strict cut-off of 165 cm will only be eligible to appear for the Detailed Medical Examination and therefore, the Medical Board would be unable to apply the said relaxation as the candidates requiring its benefit would not be presented before it.

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17. The benefit conferred by the guideline must be interpreted in a manner that it prevents it from being rendered nugatory and if the advantage of rounding off is not recognized at the PST stage, it becomes ineffective at the subsequent stage.

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18. In view of what has been discussed herein above, I am of the considered view that the respondents have wrongly disqualified the petitioners at the stage of the Physical Standard Test by ignoring the relaxation relating to rounding off, which ought to have been applied at the PST stage itself, and the respondents have misconstrued Clause 2(d) of the Office Memorandum dated 20.05.2015 by

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treating such relaxation as applicable only at the stage of the Detailed Medical Examination. Accordingly, the disqualification of the petitioners by orders dated 29.08.2025, 30.08.2025, 23.09.2025, 27.10.2025, 29.10.2025 are hereby set aside.

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19. Consequently, the petitioners, whose heights have been recorded and measured during the Physical Standard Test as 164.5 cm and above but below 165 cm, are entitled to be rounded off to 165 cm in terms of Clause 2(d) of the Office Memorandum dated 20.05.2015 and declare them eligible to participate in the subsequent stage of recruitment process, i.e. Detailed Medical Examination. It is ordered accordingly.

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20. In the result, writ petitions are allowed and disposed of.

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JUDGE

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Comparing Assistant

Ratul Talukdar v. the Union of India and Others

Case brief

What is this about?

What did the court decide?

Ratul Talukdar v. the Union of India and Others

Case brief

What is this about?

What did the court decide?

What the court decided

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