Dismissed¶12

Bakul Nath v. the Union of India and Othrs

Gauhati HC9 Jun 2026WP(C)/7405/2025

Case brief

AI extract

What is this about?

Keywords: SSC CT/GD-2025 recruitment; Constable (GD) CAPF/SSF; Rifleman (GD) Assam Rifles; Sepoy Narcotics Control Bureau; advertisement 05.09.2024; DME 25.11.2025 unfitness; RME 29.11.2025 hypertension; Office Memorandum 31.05.2021 guidelines; Clause 7(e) hospitalisation; CH BSF Patgaon blood-pressure monitoring; Specialist opinion; ECG report; Kokrajhar Medical College normotensive certificate; Review Medical Board decision final; Union of India & Ors. vs. Koushik Paul SLP(C) 738-741/2022; writ petition dismissed; interim order vacated.

What did the court decide?

Hypertension is one of the grounds on which a candidate may be declared unfit during the selection process under the guidelines, and the Court does not find any ground to interfere with the conclusions arrived at by the DME and the RME. ¶9

Bakul Nath Vs the Union of India and Othrs — Gauhati HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Dismissed

¶12

Issue for consideration

Whether the Court should interfere with the findings of the DME (25.11.2025) and the RME (29.11.2025) declaring the petitioner unfit on account of Hypertension, having regard to the guidelines in the Office Memorandum dated 31.05.2021 (including Clause 7(e)) and the petitioner's private medical certificate of being normotensive.

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Court's answer

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Ratio / Principle

Relying on the Apex Court's order in Union of India & Ors. vs. Koushik Paul (Special Leave to Appeal (C) Nos. 738-741/2022), the Court proceeded on the view that once the DME and RME have rejected, ordinarily no interference is called for (the quoted order observing that the decision of the Review Medical Board should normally be treated as final).

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Detailed headnote1 paragraphs

Gauhati High Court (Soumitra Saikia, J.), WP(C)/7405/2025, pronounced 10.06.2026: A candidate for Constable (GD)/Rifleman (GD)/Sepoy recruitment (Examination 2024, advertisement dated 05.09.2024) who cleared the written test and PST/PET was declared unfit at the DME (25.11.2025) and, on account of Hypertension, at the RME (29.11.2025), despite a subsequent certificate from Kokrajhar Medical College that he was normotensive. The Court extracted the Office Memorandum dated 31.05.2021 (Guidelines for RME in CAPFs & Assam Rifles), noting Clause 7(e)'s mandate that hypertension/tachycardia candidates be hospitalised and subjected to X-Ray, ECG and blood examinations; the respondents confirmed the medical report and ECG report were placed before the Court, and the petitioner did not deny the DME/RME findings. Holding that hypertension is a recognised ground of unfitness under the guidelines, and relying on the Apex Court's order in Union of India & Ors. vs. Koushik Paul, Special Leave to Appeal (C) Nos. 738-741/2022 (decision of the Review Medical Board normally treated as final; ordinarily no interference once DME and RME have concluded), the Court found no ground to interfere with the DME/RME conclusions and dismissed the writ petition; any interim order stood vacated and pending interlocutory applications were dismissed.

Page No.# 1/7

GAHC010277752025

undefined

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

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Case No. : WP(C)/7405/2025

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BAKUL NATH

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S/O- ADHOR NATH, VILL- TAKIMARI, HELAGARI, BILASIPARA, DIST- DHUBRI, PIN-783345, ASSAM

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VERSUS

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THE UNION OF INDIA AND OTHRS 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 (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 R.K. PURAM NEW DELHI-110066.

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5:PRESIDING OFFICER RME BOARD RECRUITMENT OF CT/GD-2025 GC CRPF GUWAHATI-781023

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

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Advocate for the Respondent : DY.S.G.I., MRS S BARUAH (C.G.C)

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– B E F O R E –

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HON’BLE MR. JUSTICE SOUMITRA SAIKIA

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Advocate for the petitioners : Mr. D. Deka, Advocate

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Advocate for the respondents : Mrs. S Baruah, CGC

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Date on which Judgment was reserved : NA

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Date of Pronouncement of Judgment : 10.06.2026

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· Whether the pronouncement is of the Operative Part of the Judgment : No · Whether the full Judgment has been Pronounced : Yes

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JUDGMENT AND ORDER

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Heard Mr. D. Deka, learned counsel for the petitioner. Also heard Mrs. S

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Baruah, learned CGC for the respondents.

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2. This writ petition is filed by the petitioner who had offered his candidature in

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response to the advertisement dated 05.09.2024 for selection and appointment

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to the post of Constable (General Duty) in the Central Armed Police Force, SSF,

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Riflemen (General Duty) in Assam Rifles and Sepoy in Narcotics Control Bureau Examination, 2024. The petitioner qualified in the written test and the Physical Standard Test/Physical Efficiency Test (PST/PET). The petitioner got qualified marks in all the categories. Thereafter, upon medical examination i.e. Detailed Medical Examination (DME) on 25.11.2025, where he was found to be unfit. Thereafter, he was presented before the Review Medical examination which was held on 29.11.2025 whereby the petitioner was declared to be unfit on account of Hypertension. After dissatisfied with the decision of the RME and DME, the petitioner got himself medically examined before the Kokrajhar Medical College where the doctor of the concerned hospital has certified that petitioner is Normotensive.

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3. Learned counsel for the petitioner also referred to the Office Memorandum dated 31.05.2021 wherein the guidelines for Review Medical examination/Review Medical Board were laid down. Referring to the said

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guidelines, learned counsel for the petitioner submits that the proper procedure by which the evaluation of the candidate is required to be made has been

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elaborately mentioned in the guidelines. It is, therefore, submitted that the petitioner be directed to re-examine before the Medical Authorities of the respondents by taking into consideration the opinion rendering by the Civil

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Medical practitioners and the procedure laid down in the Office Memorandum

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dated 31.05.2021.

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4. Ms. S. Baruah, leaned CGC, on the other hand, disputes the contention of the learned counsel for the petitioner. It is submitted that the affidavit has been

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filed in the matter and there is no violation of the guidelines given in the Office Memorandum dated 31.05.2021. It is submitted that during the Review Medical Examination, the petitioner was admitted at CH BSF Patgaon for monitoring of

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blood pressure from 28^th Nov, 2025 to 29^th Nov, 2025. All the readings of the Blood Pressure of the petitioner were more than the prescribed limit. On the

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basis of the text/examination of the petitioner and opinion of Specialist, the RME Board declared the petitioner as Unfit due to Hypertension.

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5. Learned counsel for the parties have been heard and the pleadings available

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on record have been carefully perused. It is seen that the Office Memorandum

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dated 31.05.2021 lays down the guidelines for review medical examination. The same is extracted below:

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GUIDELINES FOR REVIEW MEDICAL EXAMINATION (RME) IN CENTRAL ARMED POLICE FORCES & ASSAM RIFLES

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As per laid down guidelines, optimum care should be taken in selection of candidates as a large number of candidates are available for selection. Every candidates must be medically fit to carry out tough duties of the Force. The discharge of the candidate on medical grounds within a few months of his/her enlistment results in loss of precious time in making selection as well as loss to the government's exchequer.

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All candidates declared unfit during Detailed Medical Examination (DME) will be allowed to undergo Review Medical Examination (RME), provided they give their written consent by appending their signature on the intimation indicating the reasons for being unfit, as per Annexure-A-1.

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Henceforth, RME of candidates will be conducted in continuation of DME preferably on the next day of DME.

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The consent for RME as per Annexure-(A-1) duly signed by the candidate should be submitted within 24 hours after he/she is informed of his/her unfitness in DME.

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Nodal Force for recruitment will endeavor to keep the venue for DME/RME in the vicinity of a Composite Hospital of CAPFS or Government Medical College/Hospitals, for facilitating specialist opinion/investigations etc, if required.

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Guidelines for Review Medical Boards:-

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(a) Review Medical Board shall examine the candidate specifically for the deficiency for which the candidate has been declared unfit. [Also, the medical term used as cause of unfitness during the Initial Medical Examination may differ from that arrived at by the Review Medical Board].

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(b) It will be ensured that the Medical Officer who has conducted DME of a candidate is not part of the RME Board for the same candidate.

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(c) The defect for which candidate has been declared unfit should be examined thoroughly and the findings must be supported by proper investigation reports, if applicable.

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(d) Review Medical Board may obtain opinion of concerned specialists or super specialists of Govt. Medical College and Hospital in case of any doubt. Therefore, in cases of rejection in review medical examination, clinical findings should be corroborated with confirmatory tests/investigations/opinion of specialists/ super specialists of Govt. Hospitals/Medical Colleges/Govt. approved private medical centers, whichever and wherever applicable.

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Following examples are cited for the guidance of Review Medical Board:-

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a) In any cardiac case like valvular defects, ECG/Echocardiogram must be carried out. b) In cases of suspected lesions of chest like Hilar lymphadenitis, calcifled spots, Koch's infiltrations, any mass detected in X-Ray chest etc CT Chest should be carried out.

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c) For vascular defects like Varicose vein, vascular malformations etc, Colour Doppler should be carried out.

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d) To rule out any eye surgery like Lasik/ LASEK / PRK / PK/Glaucoma/ Squint/Pterygium Surgery etc. investigations may be carried out accordingly, viz. slit lamp examination /ophthalmoscopy /Corneal Topography/ OCT/ HVF/ Tonometry/VEP/ ERG / Synoptophore etc. should be carried out.

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e) For candidates who have been rejected on the ground of hypertension/tachycardia should be admitted/ hospitalized by the Board before giving their final opinion regarding the candidate's fitness or otherwise. The hospitalization report should indicate whether the rise in blood pressure is of transient nature due to excitement etc. or whether it is due to any organic disease. In all such cases X-Ray and electrocardiographic examinations of heart and blood examinations like cholesterol/lipid profile, S. Creatinine etc, tests should also be carried out.

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f) For any suspected case of CAD, TMT test should be conducted.

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g) Any tremor in hands or other parts of body thyrotoxicosis should be ruled out and

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neurologist's opinion should be taken.

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h) For suspected Diabetes Mellitus cases GTT and Glycosylated Hb. test should be carried out.

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i) For Knock knee, bow leg, cubitus valgus and varus deformities, X-Ray plate with findings should be attached.

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j) For any type of deafness, audiometry should be carried out.

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k) For a case of dental points less than 14, OPG should be carried out.

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6. The guidelines for Review Medical Board prescribed at Clause-7(e) clearly lays down for hypertension/tachycardia, the candidate should be hospitalized by the

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Board and the hospitalization report should indicate whether the rise the blood

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pressure is of transient nature due to excitement etc or due to any organic

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disease. In all such cases X-Ray and Electrocardiographic (ECG) examination of

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heart and blood examinations should be undertaken.

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7. It is submitted by the learned CGC that the medical report of the writ

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petitioner in respect of the medical examination undertaken by the respondent

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authorities is available. Electrocardiographic report is available and placed before

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the Court.

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8. Perusal of the writ petition does not reveal that there is any denial by the petitioner in respect of the conclusions and the findings arrived at by the DME

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and RME

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9 . In view of the above discussion and in view of the guidelines specifically

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providing that the Hypertension is one of the grounds to be declared unfit

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during the process of selection. This Court does not find any ground to interfere

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with the conclusions arrived at by the DME and RME.

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10 . In this context a reference the order of the Apex Court rendered in Union of

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India & Ors. vs. Koushik Paul in Special Leave to Appeal (C) Nos. 738- 741/2022

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clearly held that once the DME and RME has rejected the conclusions ordinarily

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no interference is called for

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11 . The relevant part of the order is extracted below:

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“In view of the peculiar facts of the present case, we are not inclined to interfere with the impugned judgments/orders. However, we must observe that normally as a rule, the decision taken by the Review Medical Board in such cases should be treated as final.

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Recording the aforesaid, the special leave petitions are dismissed. Pending applications(s), if any, shall stand disposed of.”

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12 . In view of all the above discussion, there is no merit in the writ petition.

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Accordingly, the same stands dismissed.

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13 . Interim order, if any stands vacated.

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14. Pending Interlocutory Application, if any also dismissed.

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JUDGE

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Comparing Assistant

Procedural history

How this case reached the court

AI extract

Order under challenge
Declaration of the petitioner as 'Unfit due to Hypertension' by the Review Medical Examination/RME Board (following his unfitness at the DME of 25.11.2025), pursuant to which the writ petition was filed.¶2
Review Medical Examination (RME Board), Recruitment of CT/GD-2025, GC CRPF (respondent medical authorities) · 29.11.2025
Prior proceeding
Petitioner offered candidature pursuant to advertisement dated 05.09.2024 for Constable (General Duty) in the Central Armed Police Force/SSF, Riflemen (General Duty) in Assam Rifles and Sepoy in Narcotics Control Bureau Examination, 2024.¶2
Prior proceeding
Petitioner qualified in the written test and PST/PET with qualified marks in all categories.¶2
Prior proceeding
Detailed Medical Examination (DME) held on 25.11.2025 found the petitioner unfit.¶2
Prior proceeding
Dissatisfied with the DME/RME decisions, the petitioner obtained a certificate from Kokrajhar Medical College certifying that he is Normotensive.¶2
Prior proceeding
Petitioner prayed for a direction to re-examine him before the respondents' medical authorities considering the civil medical practitioners' opinion and the procedure in the OM dated 31.05.2021.¶3
Prior proceeding
Respondents filed an affidavit asserting there was no violation of the OM dated 31.05.2021 guidelines; during the RME the petitioner was admitted at CH BSF Patgaon for blood-pressure monitoring (28-29 Nov 2025) with all readings above the prescribed limit.¶4
Prior proceeding
On the basis of the examination and Specialist opinion, the RME Board declared the petitioner Unfit due to Hypertension.¶4
Prior proceeding
Learned CGC stated that the petitioner's medical report and the Electrocardiographic report were available and placed before the Court.¶7
Prior proceeding
The Court extracted in full the OM dated 31.05.2021 'Guidelines for Review Medical Examination (RME) in Central Armed Police Forces & Assam Rifles', including Clause 7(e) requiring hospitalisation of candidates rejected for hypertension/tachycardia and corroborative investigations.¶5
Prior proceeding
The Court observed that perusal of the writ petition did not reveal any denial by the petitioner of the conclusions and findings arrived at by the DME and RME.¶8

Bakul Nath v. the Union of India and Othrs

Case brief

What is this about?

What did the court decide?

Bakul Nath v. the Union of India and Othrs

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Cases cited

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

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