Physical Fitness Non-Negotiable for Paramilitary: Delhi High Court Upholds Fitness Bar

Stressing the importance of physical fitness, the Delhi High Court has recently observed that paramilitary roles, unlike civil posts, demand higher physical strength due to the nature of duties involved.

A bench of Justice C. Hari Shankar and Justice Ajay Digpaul dismissed the plea filed by a man challenging the order of the Review Medical Board, which had declared him medically unfit due to having a single testis in his scrotum.

"The basic difference between civil employment and employment in paramilitary forces is that the required physical strength is a must for a person seeking employment in the paramilitary force," the court held.

Highlighting that Indian paramilitary forces operate in varied terrains — including high-altitude areas, deserts, and other difficult regions — the court said that personnel are required to be in optimal physical condition to ensure both their safety and effective service delivery.

In the case at hand, the petitioner had applied for the position of Medical Officer Assistant Commandant in the Central Armed Police Forces. During the recruitment process, he underwent a medical examination, during which he was found to be medically unfit on the ground that he has only one testis in his scrotum.

During the hearing, Advocate Abhay Kumar Bhargava, appearing for the petitioner, told the court that the petitioner had suffered from torsion in his left testis; it was later surgically removed due to haemorrhagic infarction.

Referring to the CAPF Medical Guidelines (2015), he argued that surgical removal of a testis due to torsion is not listed as a ground for disqualification. He also contended that other forces, such as the Army and Air Force, do not treat this condition as disqualifying.

Opposing the arguments, Central Government Standing Counsel (CGSC) Ripu Daman Bhardwaj appeared on behalf of the Union of India.

Citing Paragraph 3(e) of Chapter XIII of the CAPF Guidelines, he argued that the petitioner did not meet the medical standards required for the post and was therefore disqualified.

He added that the highest standards of physical fitness are expected from candidates seeking recruitment to the CAPF, given the arduous nature of duties performed by officers in these forces.

After considering the submissions made by both counsels, the court observed that through several decisions of the Supreme Court and various High Courts, it has been made clear that decisions of medical boards are not to be interfered with unless material irregularity or illegality is shown.

While addressing the petitioner’s contention regarding parity with other paramilitary forces or the Army, the court observed that medical standards are determined by each force individually. Therefore, it rejected the argument.

"Notably, the petitioner’s condition falls clearly within the specifications that render him ineligible for service under the existing CAPF Guidelines. This also answers the apprehension that a person cannot be declared medically unfit for having a single testis," the court noted.

Holding that the petitioner’s contention lacked merit, the court said the Review Medical Board rightly appreciated the facts and applied the CAPF Guidelines correctly.

Accordingly, the petition was dismissed.

Case Title: Shikhar Prasad v Union of India