Bheem Singh Manavat Vs the Union of India — Writ and Judicial Review | Karnataka HC (2026)

Bheem Singh Manavat Vs the Union of India — Writ and Judicial Review | Karnataka HC (2026)

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the petitioner has made out a case warranting interference under Articles 226 and 227 of the Constitution of India with the orders passed by the Central Administrative Tribunal rejecting his claim for a further re-medical examination? +1 more

Court's answer

Judicial review is directed against the decision-making process and not the decision itself; unless the expert Medical Board's opinion is shown to be vitiated by mala fides, manifest arbitrariness, violation of the prescribed procedure or patent perversity, the Court would refrain from substituting its own assessment or that of any other medical expert for the opinion of the statutory Medical Board.

Ratio / Principle

The post of Station Master is a safety category post; the Indian Railway Medical Manual specifically prescribes binocular vision as an essential requirement for A-2 medical category posts, and absence of binocular vision affects depth perception and assessment of distance relevant to the duties of the post.

Key takeaways

The contention regarding variation in recording of visual acuity in different reports does not persuade the Court; the consistent basis for declaring the petitioner medically unfit is not marginal variation in distant vision but absence of binocular vision, found identically in both the initial examination and the appellate Ophthalmic Medical Board, so the alleged discrepancies do not go to the root of the matter.ratio¶68
S.K.M. Haider ((2011) 4 SCC 700) is clearly distinguishable: the petitioner neither challenged the validity of the medical standards prescribed for Station Master under the Indian Railway Medical Manual nor questioned the A-2 classification requirement; his grievance was confined to the correctness of the expert medical assessment, so that precedent does not advance his case.ratio¶76

Detailed headnote1 paragraphs

Service law — Railway recruitment (CEN 01/2019, NTPC) — medical unfitness — Station Master (A-2 category, safety category post) — petitioner, though fit for C-1 and below, declared unfit for A-2/A-3/B-1/B-2 categories for defective binocular vision; on appeal examined by independent Ophthalmic Medical Board of three Ophthalmologists (Central Hospital, Hubballi, 03.02.2023) which reaffirmed absence of binocular vision (Worth Four Dot Test, cover-uncover test) — HELD: judicial review is directed against the decision-making process, not the decision; absent mala fides, manifest arbitrariness, violation of prescribed procedure or patent perversity, the Court will not substitute its assessment or that of other medical experts for the statutory Medical Board's opinion; IRMM prescribes binocular vision as essential for A-2 posts; discrepancies in visual acuity records immaterial as the consistent basis of unfitness was absence of binocular vision; certificates from AIIMS and other hospitals confer no vested or indefeasible right to repeated re-medical examinations once the appellate medical remedy has been availed; S.K.M. Haider v. Union of India, (2011) 4 SCC 700 distinguished (validity of medical standards not challenged here); principle in Neeraj Verma v. Union of India, W.P. No.2846/2025 (DB) relied upon; belated amendment application rejected; dismissal of Review Application upheld (review cannot re-hear merits) — Writ Petition dismissed, no costs.

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU

DATED THIS THE 8^TH DAY OF JULY, 2026

PRESENT

THE HON'BLE MR. JUSTICE S.G.PANDIT AND

THE HON'BLE DR. JUSTICE K.MANMADHA RAO

WRIT PETITION NO.17291 OF 2024 (S-CAT)

BETWEEN:

BHEEM SINGH MANAVAT, S/O SRI KHANA RAM, AGED ABOUT 31 YEARS, R/O PILI KI KHAN, DEVORIYA, BUNDI, RAJASTHAN – 323 021.

…PETITIONER

(BY SRI.SHARAN L.JAIN.,ADVOCATE)

AND:

Digitally signed by G SHREERAKSHA Location: HIGH COURT OF KARNATAKA

THE UNION OF INDIA, THROUGH GENERAL MANAGER, SOUTH-WESTERN RAILWAY, BANGALORE – 580 020.

CHAIRMAN, RAILWAY RECRUITMENT BOARD, NO.18, MILLERS ROAD, BANGALORE – 580 020.

CHIEF MEDICAL SUPERINTENDENT, SOUTH-WESTERN RAILWAY, HUBLI, KARNATAKA 580 020.

…RESPONDENTS

(BY SMT. SADHANA S. DESAI, CGC FOR R1 TO R3)

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THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO PASS THE FOLLOWING RELIEFS SET ASIDE THE ORDER PASSED BY HONBLE CENTRAL ADMINISTRATIVE TRIBUNAL, BENGALURU IN OA NO.170/00306/2023 DATED 05/07/2023 AT ANNEXUREB AND SET ASIDE THE ORDER PASSED BY HONBLE CENTRAL ADMINISTRATIVE TRIBUNAL, BENGALURU IN RA NO.5/2023 DATED 19/12/2023 AT ANNEXURE-D AND ETC.

THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and HON'BLE DR. JUSTICE K.MANMADHA RAO

ORAL ORDER

(PER: HON'BLE DR. JUSTICE K.MANMADHA RAO)

The petitioner has invoked Articles 226 and 227 of the Constitution of India calling in question the order dated 05.07.2023 passed by the Central Administrative Tribunal, Bengaluru Bench, in O.A. No.170/00306/2023 and the order dated 19.12.2023 passed in Review Application No.170/00005/2023, whereby the Tribunal declined to interfere with the decision of the Railway

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Authorities declaring the petitioner medically unfit for appointment to the post of Station Master and rejected his request for a further re-medical examination.

Heard the learned counsel appearing for the petitioner and the learned Central Government Counsel appearing for the respondents. Perused the material placed on record.

The facts, in brief, are that pursuant to Centralised Employment Notice No.CEN 01/2019 issued by the Railway Recruitment Board for recruitment to various Non-Technical Popular Category (NTPC) posts, including the post of Station Master, the petitioner applied under the Scheduled Caste category. After successfully clearing the Computer Based Tests, Computer Based Aptitude Test and document verification, he was subjected to the prescribed medical examination.

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The initial medical examination conducted by

the Railway Medical Authorities resulted in the petitioner being declared medically unfit for AYE-Two (A-2), AYEThree (A-3), BEE-One (B-1) and BEE-Two (B-2) medical categories on account of defective binocular vision, though he was found fit for CEY-One (C-1) and below categories. Since the post of Station Master requires A-2 medical classification, the petitioner preferred an appeal seeking re-medical examination in terms of the applicable recruitment procedure.

Pursuant thereto, the respondents constituted an Ophthalmic Medical Board consisting of three Ophthalmologists at the Central Hospital, Hubballi, which examined the petitioner on 03.02.2023. The Medical Board recorded that although the petitioner's distant vision, near vision and colour vision were within the prescribed parameters, he did not possess binocular vision as evidenced by the Worth Four Dot Test and cover-uncover test. Consequently, the Medical Board reiterated that the

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petitioner was unfit for A-2, A-3, B-1 and B-2 medical categories due to defective binocular vision and fit only for C-1 and below categories. A speaking order was thereafter issued by the competent authority.

Aggrieved thereby, the petitioner approached the Central Administrative Tribunal in O.A. No.170/00306/2023 seeking quashing of the medical opinion and a direction for yet another re-medical examination. The Tribunal, by order dated 05.07.2023, dismissed the Original Application holding that binocular vision is an essential requirement under the Indian Railway Medical Manual (IRMM) for A-2 medical category posts and that the petitioner had already been examined by an independent Medical Board constituted in accordance with the prescribed procedure. The Review Application preferred thereafter also came to be dismissed on 19.12.2023.

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Assailing the aforesaid orders, learned counsel

for the petitioner contends that the Medical Board conducted the examination in haste; that there are discrepancies in the recorded visual acuity in different reports; and that certificates obtained from AIIMS and other reputed hospitals indicate that the petitioner satisfies the medical requirements for A-2 category. It is submitted that in the interest of fairness, one final opportunity ought to be granted for re-medical examination before an independent Medical Board.

Per contra, learned Central Government Counsel submits that the petitioner has already availed the statutory remedy of appeal against the initial medical examination and has been examined by an independent Ophthalmic Medical Board comprising three specialists, none of whom had participated in the initial examination. It is contended that both examinations consistently found absence of binocular vision, which is a mandatory qualification for A-2 medical category under the IRMM. It

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is further submitted that this Court, while exercising jurisdiction under Articles 226 and 227 of the Constitution, would not substitute its opinion for that of an expert Medical Board in the absence of arbitrariness, mala fides or procedural illegality.

Having heard the learned counsel for the parties and having perused the material placed on record, the following point arises for consideration:

"Whether the petitioner has made out a case warranting interference under Articles 226 and 227 of the Constitution of India with the orders passed by the Central Administrative Tribunal rejecting his claim for a further re- medical examination?"

The undisputed facts disclose that the petitioner

participated in the recruitment process pursuant to Centralised Employment Notice No. CEN 01/2019 for the

post of Station Master. After successfully clearing the written examinations and document verification, he underwent the prescribed medical examination. The petitioner was declared medically unfit for AYE-Two (A-2),

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AYE-Three (A-3), BEE-One (B-1) and BEE-Two (B-2) medical categories on account of defective binocular vision.

Significantly, the matter did not end there. The recruitment notification as well as the applicable procedure provide an opportunity to a candidate to seek re-medical examination. Availing such remedy, the petitioner preferred an appeal, whereupon the competent authority constituted an Ophthalmic Medical Board comprising three Ophthalmologists, distinct from the medical officers who had participated in the initial examination. The Board examined the petitioner independently and again found that though his distant vision, near vision and colour vision were within acceptable limits, he lacked binocular vision as demonstrated by the Worth Four Dot Test and the coveruncover test. Consequently, the petitioner was again declared unfit for A-2 medical category. These factual aspects are not in dispute.

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The principal contention urged on behalf of the petitioner is that medical certificates issued by AIIMS and certain private and Government hospitals indicate that he satisfies the requirements of A-2 category and, therefore, one more opportunity for re-medical examination deserves to be granted. The submission does not merit acceptance.

The post of Station Master is admittedly a safety category post. The medical standards prescribed for such post are not merely matters of administrative convenience but are intended to ensure operational safety and public interest. The Indian Railway Medical Manual specifically prescribes binocular vision as an essential requirement for candidates seeking appointment to A-2 medical category posts. The Medical Board has recorded that absence of binocular vision affects depth perception and assessment of distance, both of which are relevant to the discharge of duties attached to the post of Station Master.

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It is trite that judicial review is directed against the decision-making process and not the decision itself. Unless the opinion of the expert Medical Board is shown to be vitiated by mala fides, manifest arbitrariness, violation of the prescribed procedure or patent perversity, this Court would refrain from substituting its own assessment or that of any other medical expert for the opinion of the statutory Medical Board.

Equally, the contention regarding variation in the recording of visual acuity in different reports does not persuade this Court to take a different view. The consistent basis on which the petitioner has been declared medically unfit is not the marginal variation in distant vision but the absence of binocular vision. Both the initial examination and the appellate Ophthalmic Medical Board have arrived at the same conclusion on this aspect. Therefore, the alleged discrepancies in visual acuity do not go to the root of the matter.

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Learned counsel for the petitioner placed reliance on the decision of the Hon'ble Supreme Court in

S.K.M. Haider v. Union of India & Others, (2011) 4

SCC 700. In the said case, the appellant, who was working as a Luggage Porter, was selected for promotion to the post of Ticket Collector but was denied promotion on the ground that he had not been declared medically fit in B-2 medical category under the provisions of the Indian Railway Medical Manual. The Hon'ble Supreme Court examined the nature of duties attached to the post of Ticket Collector vis-à-vis the medical standards prescribed there for and held that the prescription of B-2 medical classification for the said post lacked a rational nexus with the duties required to be discharged by a Ticket Collector. On that reasoning, the Court held that the denial of promotion on the basis of the prescribed B-2 medical classification was unsustainable. In the present case, however, the controversy stands on an altogether different footing. The petitioner has neither challenged the validity

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of the medical standards prescribed for the post of Station Master under the Indian Railway Medical Manual nor questioned the requirement of A-2 medical classification for the said post. The grievance of the petitioner is confined to the correctness of the medical opinion rendered by the Railway Medical Board declaring him unfit on account of defective binocular vision. Thus, the issue before this Court is not the validity or reasonableness of the prescribed medical standard but the correctness of the expert medical assessment. Consequently, the ratio laid down in S.K.M. Haider is clearly distinguishable and does not advance the petitioner's case.

Reliance was also placed on certain orders of the Central Administrative Tribunal directing constitution of a fresh Medical Board in cases where the candidates had questioned the correctness of the medical opinion. Those decisions turned on their own peculiar facts. In the present case, the petitioner was initially examined by the Railway Medical Authorities and, on his appeal, was again

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examined by an independent Ophthalmic Medical Board comprising three specialists, who unanimously recorded that the petitioner suffers from defective binocular vision and is consequently unfit for A-2 medical category. Thus, the petitioner has already availed the appellate medical remedy contemplated under the applicable procedure. In such circumstances, no vested or indefeasible right accrues to the petitioner to seek repeated re-medical examinations merely because he has secured opinions from other medical institutions.

On the other hand, learned Central Government Counsel placed reliance on the decision of the Division Bench of this Court in W.P. No.2846/2025 ( Neeraj Verma v. Union of India & Others ) . In the said case also, the petitioner, aspiring for appointment to the post of Station Master, questioned the opinion of the Railway Medical Board and relied upon certificates issued by other Ophthalmologists to contend that he was medically fit. Ultimately, the Division Bench declined to interfere with

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the opinion of the Medical Board and reiterated the limited scope of judicial review over expert medical opinions. The principle enunciated therein squarely applies to the facts of the present case.

It is also pertinent to note that the petitioner has filed an application seeking amendment of the writ petition at this belated stage. The writ petition has remained pending for a considerable period, the parties have completed their pleadings, the matter has undergone several rounds of litigation before the Tribunal, including the Original Application and the Review Application, and the case has been heard extensively before this Court. The proposed amendment does not seek to bring on record any subsequent event or a material fact which could not have been pleaded earlier despite due diligence. Entertaining such an application at this stage would amount to permitting the petitioner to alter the nature and scope of the challenge after the controversy has substantially crystallised. The petitioner cannot be

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permitted to improve his case by introducing new pleadings after having unsuccessfully prosecuted the proceedings before the Tribunal and after the matter has reached the stage of final adjudication before this Court. Therefore, the application for amendment does not merit consideration.

Insofar as the challenge to the order dated 19.12.2023 passed in Review Application No.170/00005/2023 is concerned, we find that the Tribunal has rightly held that no error apparent on the face of the record was made out warranting exercise of review jurisdiction. A perusal of the Review Application would indicate that the grounds urged therein were substantially a reiteration of the contentions advanced in the Original Application, seeking a re-appreciation of the very same material. Review jurisdiction cannot be invoked to re-hear or re-argue the matter on merits. We, therefore, find no infirmity in the order rejecting the Review Application.

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In the light of the above discussion, this Court is satisfied that the Tribunal has correctly appreciated the factual and legal position and has rightly declined to interfere with the medical opinion rendered by the expert Ophthalmic Medical Board. Equally, no infirmity is found in the order rejecting the Review Application. Accordingly, the point for consideration is answered in the Negative.

In view of the foregoing discussion, no case is made out for interference with the impugned orders passed by the Tribunal in exercise of jurisdiction under Articles 226 and 227 of the Constitution of India.

ORDER

(i) The Writ Petition is dismissed .

(ii) Consequently, the order dated 05.07.2023 passed in O.A. No.170/00306/2023 and the order dated 19.12.2023 passed in Review Application No.170/00005/2023 by the Central

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Administrative Tribunal, Bengaluru Bench, do not

call for interference.

(iii) Pending interlocutory applications, if any,

stand disposed of.

(iv) No order as to costs.

SD/(S.G.PANDIT) JUDGE

SD/(DR.K.MANMADHA RAO) JUDGE

BNV

List No.: 1 Sl No.: 34