Bombay High Court
Aniket Sunil Jadhav vs Union Of India Thru. Secretary And Ors on 10 October, 2025
Author: Ravindra V. Ghuge
Bench: Ravindra V. Ghuge
Digitally
2025:BHC-AS:44101-DB
signed by
GAURI AMIT
GAURI GAEKWAD
AMIT Date:
GAEKWAD 2025.10.10 957.WP-13359-2025.odt
21:09:06
+0530
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CIVIL APPELLATE JURISDICTION
WRIT PETITION NO.13359 OF 2025
Aniket Sunil Jadhav
Age 23 years, Occ.- Student,
R/at - At post Phone bk.
Tal. Dharangaon,
Dist. Jalgaon - 465 105 ... Petitioner
Versus
1. Union of India
Through its Secretary,
Ministry of Home Affairs,
(Department of Personnel
and Training), North Block,
Central Secretariat,
New Delhi
2. Staff Selection Commission,
Commercial Karmik,
Block No.12,
Central Government Complex,
Lodhi Road,
New Delhi - 110 003
3. The Director General,
CRPF (Recruitment Branch)
East Block 07, Level 4, Sector 1,
R. K. Puram,
New Delhi - 110 066
4. Deputy Commandant,
Member-I (PST & PET),
At - CRPF, Talegaon,
Vishanpuri,
Pune 410 507 ... Respondents
----
Mr. Venkatesh A. Shastry for the Petitioner.
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Mr. Rui Rodrigues a/w. Mr. Vinit Jain and Ms. Priyanka Chavan for
Respondent No.1.
----
CORAM : RAVINDRA V. GHUGE
&
ASHWIN D. BHOBE, JJ.
DATE : 10th OCTOBER, 2025
ORAL JUDGMENT : (PER RAVINDRA V. GHUGE, J.)
1. Heard Mr. Shastry, the learned Advocate for the
Petitioner and Mr. Rodrigues, the learned Advocate for Respondent
No.1.
2. Rule. Rule made returnable forthwith. Heard the
Petition finally with the consent of the learned Advocates appearing
for the parties.
3. The Petitioner being 23 years of age is aspirant of
joining Central Armed Forces.
4. The Petitioner is aggrieved by the Physical Standard
Test (PST) Rejection Slip, by which the Petitioner is disqualified
from appearing for Detailed Medical Examination (DME) of
Constable (GD) in Central Armed Police Forces (CAPFs) and SSF,
Rifleman (GD) in Assam Rifles, and Sepoy in Narcotics Control
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Bureau Examination - 2025, on the ground that the height of the
Petitioner is less than the prescribed height.
5. Vide Notice dated 5th September 2024 (said Notice),
Respondent No.2 invited applications from eligible candidates, for
the post of Constable, General Duty (GD) in Central Armed Police
Forces (CAPFs) and SSF, Rifleman (GD) in Assam Rifles and
Sepoy in Narcotics Control Bureau Examination - 2025. Said
Notice prescribes 3 stages for the recruitment of the candidate/s for
the said post, viz. (1) Computer Based Examination (CBT);
(2) Physical Standard Test (PST) and Physical Efficiency Test
(PET); and (3) Detailed Medical Examination (DME).
6. The Petitioner being eligible and satisfying the requisite
qualifications prescribed in the said Notice applied for the said post.
Admit card was issued to the Petitioner to appear for the Computer
Based Examination.
7. The Petitioner qualified in the Computer Based
Examination, as such was called to appear before Respondent No.4
Board at CRPF, Pune, for Physical Standard Test and Physical
Efficiency Test. The Petitioner successfully cleared the Physical
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Efficiency Test and thereafter underwent the Physical Standard Test.
8. The Petitioner was declared disqualified in the Physical
Standard Test on the ground that the height of the Petitioner was
recorded as 169.6 cm, which was less than the standard height viz.
170 cm, prescribed in the said Notice. Accordingly, Respondent
No.4 issued PST Rejection Slip dated 2nd September, 2025 to the
Petitioner.
9. Petitioner is, therefore, before this Court seeking the
following substantive reliefs :-
(A) That this Honourable High Court be pleased to
pass writ of mandamus or the order in the similar
nature and extend the benefit of relaxation to the
Petitioner as contemplated in clause 2(d) of "Revised
Uniform Guidelines" dated 20th May 2015 and
thereby to give direction to the Respondents to set
aside the Rejection Slip dated 2nd September, 2025
and declare the Petitioner to be eligible for Detailed
Medical Examination (DME).
10. Mr. Shastry, the learned Advocate for the Petitioner
submits that Respondents have erroneously disqualified the
Petitioner. He submits that clause 2(d) of Uniform Guidelines for
Medical Examination in Central Armed Police Forces and Assam
Rifles for GOs & NGOs dated 20th May, 2015 (Said Guidelines)
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applicable to the recruitment, lays down that while measuring the
height fraction of cm less than 0.5 cm will be ignored and 0.5 cm
and more will be rounded off to the next higher cm, standard height.
He, therefore, submits that the Petitioner is entitled to the relaxation
in terms of clause 2(d) of the "Said Guidelines" and as such is
required to be declared as qualified in the Physical Standard Test so
as to move to DME. He relies on the orders passed by the Madhya
Pradesh High Court in the case of Arun Kalmodiya v/s. Union of
India1; by the Calcutta High Court in the case of Anuj Bala v/s.
Union of India2 and connected matters; and by the Punjab and
Haryana High Court in the case of Union of India v/s. Kuldeep3. He
submits that grave prejudice and injury would be caused to the
Petitioner if benefit under clause 2(d) of the "Said Guidelines" is not
extended to the Petitioner and, therefore, seeks indulgence of this
Court in its extra ordinary writ jurisdiction.
11. Mr. Rodrigues, the learned Advocate for Respondent
No.1 opposes the present Petition. He submits that the provisions in
the Said Guidelines of rounding off the fraction of height is
1. Writ Petition No.34269 of 2024 decided 17th February, 2025.
2. Writ Petition No.21766 of 2025 decided on 12th September, 2025.
3. L.P.A. No. 1724 of 2024 decided on 24th July, 2024.
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applicable at the stage of Detailed Medical Examination and not at
the Physical Standard Test stage. He supports the disqualification of
the Petitioner.
12. Having considered the rival contention, the issue which
falls for consideration is whether the Petitioner can be given
relaxation in the height, in terms of clause 2(d) of the Said
Guidelines?
13. The learned Advocate for the Petitioner submits that the
minimum height requirement for the "Maratha" category is 165 cm,
whereas for the "OBC" category it is 170 cm. The Petitioner has a
height of 169.6 cm and falls short by 0.4 cm of the requisite height
for qualifying in the Physical Standard Test, which is not in dispute.
14. As per the scheme of examination for the post of
Constable, General Duty (GD) in Central Armed Police Forces
(CAPFs) and SSF, Rifleman (GD) in Assam Rifles and Sepoy in
Narcotics Control Bureau Examination- 2025, Computer Based
Examination (CBT), Physical Standard Test (PST) & Physical
Efficiency Test (PET) and Detailed Medical Examination (DME),
are mandatory. All theses examinations are required to be conducted
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as per the Said Guidelines.
15. Clause 12, 12.1, 12.2, 12.4, 12.5 and 12.6 of the said
Notice relevant for the issue/s as raised in the petitions, are
extracted herein below :-
12 Scheme of Examination:-
12.1 Computer-Based Examination : The
Computer-Based Examination will consist of
one Objective Type Paper containing 80
questions carrying 2 marks each with the
following composition :-
Part Subject Number of Maximum Duration/
Questions Marks Time
Allowed
and Reasoning
and General
60 Minutes
Awareness
Mathematics
12.2 Physical Standard Test (PST) Physical
Efficiency Test (PET) : Based on the
performance in the CBE, candidates will be
shortlisted for PST/PET by the Commission.
Physical Standard Test (PST) and Physical
Efficiency Test will be conducted at various
centres finalized by the CAPFs. Detailed scrutiny
of candidates' eligibility/documents will be
undertaken at the time of DME/DV. Therefore,
it will be the responsibility of the candidates to
verify their eligibility as prescribed in this Notice
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before appearing for CBE/PST/PET. Candidates
shortlisted for PST/PET will be asked to go
through biometric verification followed by
PST/PET. The PST shall include measurements
of height, weight & Chest (as applicable).
12.4 Physical Efficiency Test (PET):
Candidates have to clear the race within the
following limits :-
Event Male Female Remarks
5 Kms in 24 1.6 Kms in 8 For candidates other
minutes minutes than those belonging to
Race the Ladakh Region
1.6 Kms in 7 800 meters in 5 For candidate of
minutes minutes Ladakh Region
12.5 Physical Standard Test (PST) : Physical
Standard for the posts are as follows:-
12.5.1 Height :
12.5.1.1 Male 170 cms
12.5.1.2 Female 157 cms
12.5.1.3 Few categories of candidates are allowed
relaxation in the heights mentioned above.
Relaxed standard of height for such
candidates are as follows:
Sr. No. Relaxation in Height to few categories of Male Femal
Candidate (Cms) e
(Cms)
(a) All candidates belonging to Scheduled Tribes. 162.5 150.0
(b) All Scheduled Tribes Candidates of North 157.0 147.5
Eastern States (NE States).
(c) All Scheduled Tribes Candidates of Left- 160.0 147.5
Wing Extremism affected districts.
(d) Candidates falling in the categories of 165.0 155.0
Garhwalis, Kumaonis Dogras, Marathas and
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Candidates belonging to the States/ UTs of
Assam, Himachal Pradesh, Jammu and
Kashmir and Ladakh.
(e) Candidates hailing from the North-Eastern 162.5 152.5
States of Arunachal Pradesh, Manipur,
Meghalaya, Mizoram, Nagaland, Sikkim and
Tripura.
(f) Candidates hailing from Gorkha Territorial 157.0 152.2
Administration (GTA) comprising of the
three Sub-Divisions of Darjeeling District
namely Darjeeling, Kalimpong and
Kurseong and includes the following
"Mouzas" Sub-Division of these Districts: -
(1)Lohagarh Tea Garden (2) Lohagarh Forest
(3) Rangmohan (4) Barachenga (5) Panighata
(6) ChotaAdalpur (7) Paharu (8) Sukna Forest
(9) Sukna Part-I (10) Pantapati Forest-I (11)
Mahanadi Forest (12) Champasari Forest (13)
SalbariChhatpart-II (14) Sitong Forest (15)
Sivoke Hill Forest (16) Sivoke Forest (17)
ChhotaChenga (18) Nipania.
(Emphasis Supplied )
12.6 Medical Examination / Document
Verification: Candidates will be
shortlisted for Detailed Medical Examination
(DME) / Document Verification from the pool of
candidates who qualify the PST / PET.
16. Vide Office Memorandum bearing No. A.VI-1/2014-
Rectt (SSB) dated 20th May, 2015, the Government of India,
Ministry of Home Affairs, has approved the Guidelines for
Recruitment Medical Examination in CAPFs & AR, for
implementation. Clause 2 (d) of the Said Guidelines, as relevant
are extracted herein below :-
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"2. GENERAL INSTRUCTIONS FOR RECRUITMENT
BOARD:
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."
(emphasis supplied.)
17. The Petitioner has qualified in the Computer Based
Examination as well as Physical Efficiency Test. Clause 12.6 of the
said Notice makes a reference to candidates from the pool of
candidates qualifying the Physical Standard Test (PST) & Physical
Efficiency Test (PET) being shortlisted for Detailed Medical
Examination (DME) / Document Verification. The Petitioner having
failed to qualify in the Physical Standard Test due to his height
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measurement being below the prescribed standard of 170 cms, is
precluded from proceeding to the next Detailed Medical
Examination stage.
18. Clause 2(d) of the Said Guidelines, which provides for
rounding off of the height to the next higher centimeter would be
applicable at the stage of Physical Standard Test. The benefit
conferred by the Said Guidelines was required to be extended to the
Petitioner at the Physical Standard Test stage. Disqualifying the
Petitioner at the stage of Physical Standard Test on account of his
height being 169.6 cm, is illegal and arbitrary. We are of the
considered opinion that the Petitioner is entitled to the benefit of
height relaxation in terms of Clause 2(d) of the Said Guidelines by
rounding off the fraction of the height to the next higher centimeter.
19. In view of the above, this Petition is allowed in terms of
prayer clause (a). The Petitioner is hereby given benefit of the
relaxation in terms of Clause 2(d) of the Said Guidelines,
consequently Respondents are directed to consider the height of the
Petitioner which is 169.6 cm, thereby declaring the Petitioner
eligible for the Detailed Medical Examination.
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20. Rule made absolute in the above terms. There shall be
no orders as to costs.
(ASHWIN D. BHOBE, J.) (RAVINDRA V. GHUGE, J.)
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