Madras High Court
M.Sriram vs The Under Secretary For Government Of ... on 28 October, 2025
Author: G.K.Ilanthiraiyan
Bench: G.K.Ilanthiraiyan
W.P.No.33420 of 2025 etc. batch
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED : 28.10.2025
CORAM
THE HONOURABLE MR. JUSTICE G.K.ILANTHIRAIYAN
W.P.Nos.33420, 35311, 35317, 35321, 35323, 35353, 35357, 35360, 35364,
36209, 36212, 36216, 36230, 36233, 36543, 36547, 36550, 36551, 36553,
36623, 36624, 36626, 36630, 36632, 36659, 36663, 36669, 36671, 37108,
37110, 37111, 37167, 37171, 37220, 37222, 37228, 37238, 37244, 37247,
37221, 37224, 37227, 37229, 37340, 37344, 37347, 37359, 37364, 37367,
37404, 37414, 37417, 37435, 37440, 37547, 37551, 37554, 37559, 37563,
37560, 37567, 37570, 37573, 37578, 37582, 37589, 37590, 37591, 375924,
37604, 37606, 37608, 37609, 37612, 37683, 37687, 37688, 37694, 37696,
37698, 37745, 37747, 37749, 37750, 37751, 37753, 37946, 37948, 37951,
37953, 37955, 38303, 38344, 38358, 38368, 38384, 38343, 39743, 39746,
39748, 39751, 39770, 39911, 39914, 39917, 39918, 39920, 39979, 40063,
40141, 40177, 40197, 40286 and 40289 of 2025
and
W.M.P.Nos.37554, 37555, 39524, 39526, 39529, 39531, 39534, 39536,
39538, 39539, 39574, 39577, 39580, 39581, 39584, 39586, 39587, 39589,
40469, 40472, 40475, 40476, 40480, 40481, 40498, 40496, 40502, 40503,
40847, 40851, 40855, 40858, 40863, 40942, 40944, 40946, 40948, 40951,
40991, 40997, 41000, 41003, 41526, 41528, 41529, 41602, 41607, 41651,
41647, 41654, 41662, 41669, 41670, 41648, 41649, 41653, 41655, 41773,
41775, 41777, 41796, 41798, 41800, 41841, 41851, 41855, 41893, 41897,
42004, 42010, 42013, 42017, 42021, 42018, 42024, 42027, 42030, 42035,
42044, 42051, 42056, 42061, 42063, 42081, 42083, 42086, 42087, 42088,
42163, 42167, 42168, 42171, 42173, 42174, 42210, 42211, 42212, 42215,
42216, 42218, 42387, 42389, 42390, 42391, 42392, 42823, 42824, 42878,
42879, 42892, 42895, 42904, 42906, 42915, 42918, 42876, 42877, 44655,
44656, 44658, 44659, 44664, 44665, 44667, 44668, 44685, 44687, 44840,
44841, 44842, 44844, 44846, 44897, 44899, 45011, 45013, 45084, 45087,
45126, 45128, 45149, 45151, 45241, 45242, 45244 and 45245 of 2025
1/22
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W.P.No.33420 of 2025 etc. batch
W.P.No.33420 of 2025
M.Sriram ... Petitioner
Vs
1. The Under Secretary for Government of India,
Staff Selection Commission Ministry of Personnel,
Public Grievances and Pensions Department and
Personnel and Training,
Block No.12, CGO Complex,
Lodhi Road,
New Delhi – 110 003.
2. Regional Director (Southern Region),
Staff Selection Commission,
2nd Floor, EVK Sampath Building,
DPI Campus, College Road,
Chennai, Tamil Nadu – 600 006.
3. The Directorate General
CRPF (Recruitment Branch)
East Block 07, Level – 4
Sector 01, R.K.Puram,
New Delhi – 110 066.
4. Second in Command
(IRLA-6065) RANGE: BLR, CRPF
Presiding Officer of PET/PST Board,
Rectt of CT/GF – 2025
In CAPFS, SSF and Assam Rifles
Rectt. Centre: GC, CRPF, Avadi. ... Respondents
Writ Petition is filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorarified Mandamus, calling for the records
2/22
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W.P.No.33420 of 2025 etc. batch
of the fourth respondent dated 21.08.2025 relating to the petitioner Roll
No.8201004334 with recruitment for the post of Constable (GD) in CRPF,
quash the same as null and void and consequentially directing the fourth
respondent to conduct a fresh Physical Efficiency Test (PETP for the
petitioner for the post of Constable (GD) in CRPF in any date that may be
fixed by this Court.
W.P.Nos.33420, 35311, 35317, 35321, 35323,
35353, 35357, 35360, 35364, 36209, 36212,
36216, 36230, 36233, 36543, 36547, 36550,
36551, 36553, 39743, 39746, 39748, 39751,
39770, 38303, 38344, 38358, 38368, 38384,
38343, 40286 and 40289 of 2025 of 2025
For Petitioner : Mr.T.Shunmugarajeswaran
For Respondents : Mr.R.Rajesh Vivekananthan,
Deputy Solicitor General of India
and Mr.N.Manikandan,
Central Government Standing Counsel
W.P.Nos.36623, 36624, 36626, 36630, 36632, 36659,
36663, 36669, 36671, 37108, 37110, 37111, 37167,
37171, 37220, 37222, 37228, 37238, 37244, 37247,
37221, 37224, 37227, 37229, 37340, 37344, 37347,
37359, 37364, 37367, 37404, 37414, 37417, 37435,
37440, 37547, 37551, 37554, 37559, 37563, 37560,
37567, 37570, 37573, 37578, 37582, 37589, 37590,
37591, 375924, 37604, 37606, 37608, 37609, 37612,
37683, 37687, 37688, 37694, 37696, 37698, 37745,
37747, 37749, 37750, 37751, 37753, 37946, 37948,
37951, 37953, 37955, 39911, 39914, 39917, 39918 and
39920 of 2025
3/22
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W.P.No.33420 of 2025 etc. batch
For Petitioner : Mr.Dhanaram Ramachandran
For Respondents : Mr.R.Rajesh Vivekananthan,
Deputy Solicitor General of India
and Mr.N.Manikandan,
Central Government Standing Counsel
W.P.Nos.39979, 40063, 40141, 40177 and 40197 of 2025
For Petitioner : Mr.V.R.Annagandhi
For Respondents : Mr.R.Rajesh Vivekananthan,
Deputy Solicitor General of India
and Mr.N.Manikandan,
Central Government Standing Counsel
COMMON ORDER
These writ petitions have been filed challenging the Physical
Efficiency Test (hereinafter referred to as 'the PET') rejection slip and
Physical Standards Test (hereinafter referred to as 'the PST') rejection slip
during Central Reserve Police Force Recruitment 2025.
2. Heard the learned counsel for both sides and perused the
materials available on record.
3. The Staff Selection Commission (SSC) issued a recruitment
notification dated 05.09.2024, inviting applications from eligible and
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W.P.No.33420 of 2025 etc. batch
aspiring candidates for the post of Constable (GD) in the Central Armed
Police Forces (CAPFs) and SSF, Rifleman (GD) in Assam Rifles, and Sepoy
in the Narcotics Control Bureau - Examination – 2025. For the above-said
post, a total of 39,481 (35,612 for male and 3,869 for female) vacancies
were notified all over India. A total of 12,670 (11,325 for male and 1,345 for
female) candidates were called for PST/PET at Group Centre, CRPF Avadi,
Chennai, which was scheduled from 20.08.2025 to 03.09.2025.
4. As per the guidelines, after clearing the Computer Based
Examination (CBE) conducted by the Staff Selection Commission, the
candidates are required to appear for the PET and PST. These stages are
conducted under the supervision of the Central Reserve Police Force, which
is the nodal force for the Central Armed Police Forces (hereinafter referred
to as "the CAPFs") recruitment. The PET involves timed running events,
while the PST includes verification of height, chest, and weight
measurements with respect to the prescribed standards.
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5. In the PST, the minimum requirements are prescribed, which
read as follows:-
● “Height: Male – 170 cm; Female – 157 cm. Scheduled Tribe
candidates – Male 162.5 cm, Female 150 cm. Candidates
belonging to North-Eastern States, Gorkhas, Garhwalis,
Kumaonis, Dogras, Marathas, and Lakshadweep – Male 165 cm,
Female 155 cm.
● Chest (for male candidates): 80 cm (unexpanded) with a minimum
expansion of 5 cm. For Scheduled Tribe Candidates – 76 cm
(unexpanded) with a minimum expansion of 5 cm.
● Weight: Proportionate to height and age as per medical standards.
6. In the PET, the minimum requirements are prescribed, which
reads as follows:-
● Male candidates must complete a race of 5 kilometres in 24
minutes, and candidates from the Ladakh region must complete
1.6 kilometres in 7 minutes.
● Female candidates must complete a race of 1.6 kilometres in 8.5
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minutes, and candidates from the Ladakh region must complete
800 metres in 5 minutes.
7. Only those candidates who qualify in the PET and PST are
admitted to the Detailed Medical Examination (hereinafter referred to as
"the DME"), which is conducted in accordance with the uniform medical
guidelines applicable to the CAPFs. After clearing the DME, the eligible
candidates are subjected to a Revenue Medical Examination (RME). After
clearing the DME/RME, Document Verification (DV) will be done, wherein
the eligibility of candidates is confirmed with reference to educational
qualifications, caste and domicile certificates, and other documents. The
final merit list and allocation of candidates to various forces are thereafter
prepared by the Staff Selection Commission on the basis of marks obtained
in the Computer-Based Examination (CBE), with due consideration to
reservation categories and NCC bonus marks, wherever applicable. The
successful candidates will be appointed to their selected respective posts.
All the petitioners cleared the CBE and were subjected to PET and PST.
However, the petitioners were issued PST and PET rejection slips on the
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W.P.No.33420 of 2025 etc. batch
ground that they did not meet the required height and failed to complete the
PET within the eligibility time fixed to qualify.
8. The learned counsel for the petitioners submitted that the PET
was conducted at Group Centre, CRPF Avadi, Chennai, in two grounds. The
grounds were not standard, and the petitioners' running track was filled with
M-sand. Therefore, it was slippery, and the petitioners could not complete
5,000 meters within 24 minutes. Each lap of the ground is 400 meters; 13
laps come around 5,200 meters, which is more than the distance fixed for
the PET. For female candidates, the distance for the PET was fixed at 1.6
kilometers. Therefore, they had to run for 4 laps. Each lap distance is 400
meters, which is more than the distance fixed in the guidelines for the PET.
They also exhibited videographs of the PET conducted by the Staff
Selection Commission.
9. The learned counsel for the petitioners further submitted that
the width of the track was less than 10 feet. At a time, the respondents
conducted a race for 100 candidates. Therefore, it was very difficult to
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complete 13 laps within the stipulated time. There was mud and it was also
slippery. Therefore, the candidates had to go one by one and could not take
sides over the other person who ran before them. In fact, some of the
petitioners had qualified in the previous recruitment in the PST. However,
now the device used to measure the height is not upto the standard, and as
such, the height of the petitioners differ from the previous year's
measurements. Digital instruments are prone to calibration variations and
measurement errors, particularly when compared to manual methods used in
previous years. A negligible shortfall of 0.4 cm falls within the margin of
error of any device and cannot be treated as a genuine deficiency.
10. They also submitted that the use of digital measurement
devices to record height is inconsistent and unreliable. Therefore, the PST
and PET rejection slips are wholly unjustified. As per the Revised
Guidelines for Recruitment Medical Examination in Central Armed Police
Forces and Assam Rifles, Clause 2(d) of the General Instructions for the
Recruitment Board states that in borderline cases of overweight, BMI
should also be considered to arrive at a conclusion, and a variation of 5 kg
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W.P.No.33420 of 2025 etc. batch
+/- from the minimum/maximum limit may be accepted. Similarly, while
measuring height, a fraction of cm less than 0.5 will be ignored, and 0.5 cm
& more will be rounded off to the next higher cm. A standard height-weight
chart is attached at Annexure-I. Therefore, those whose weight is measured
in fractions should be rounded off. If rounded off, the petitioners would be
eligible for medical examination by fulfilling the height criteria. Hence, the
rejection on such a slender margin violates Articles 14 and 16 of the
Constitution of India.
11. The learned counsel for the petitioners further submitted that
there was no procedural fairness in the conduct of the PST. A single digital
measurement, without providing any opportunity for re-measurement, cross-
verification, or consideration of official medical certificates, is not fair. The
hurried and mechanical approach of the PST Board reflects procedural
irregularities, which undermine the transparency and fairness of the
selection process. The learned counsel for the petitioners also relied upon
the judgment of the Hon'ble Madhya Pradesh High Court in Arun
Kalmodiya vs. Union of India & Ors. (W.P. No. 34269 of 2024), which
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dealt with a similar issue regarding disqualification at the PST stage and
further held that any fraction below 0.5 cm is to be ignored, and 0.5 cm and
above must be rounded off to the next higher cm.
12. In fact, the guidelines of the Recruitment Medical
Examination were distorted, and the contention was rejected, holding that
the applicability of rounding off cm only to the detailed medical
examination cannot be accepted; preferring such an interpretation was
contrary to the recruitment scheme. If rounding off was not applied at the
PST stage itself, a candidate would never even reach the DME stage. Thus,
the benefit of Clause 2(d) must necessarily apply at the PST.
13. The learned counsel for the petitioners also relied upon the
judgment of this Court in M.M. Karthikeyan vs. The Tamil Nadu Public
Service Commission & Ors. (W.P. Nos. 13657 and 14840 of 2024, dated
11.06.2024), which held that minor variations in height measurement are
scientifically established to vary due to diurnal changes and other factors,
and it cannot be treated as determinative of eligibility. The judgment further
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observed that strict reliance on digital measurement alone leads to manifest
arbitrariness and that the proper course is to apply the rounding-off rule,
supported by scientific evidence and established jurisprudence. Further, the
decision of this Court in M. Priya vs. The Chairman, Tamil Nadu
Uniformed Services Recruitment Board (W.P. (MD) No. 2971 of 2024,
etc., batch, dated 18.03.2024) directed the respondents to relax the required
height measurement by 0.5 cm in order to prevent marginal and mechanical
disqualification of the candidates. This Court further held that height
measurements must be conducted in a fair and transparent manner, using
scientifically approved digital measurement devices to avoid discrepancies
and errors.
14. The respondents filed counter-affidavits, and the submission
made by the learned Deputy Solicitor General of India and the Central
Government Standing Counsel appearing for the respondents revealed that,
as per the eligibility criteria, the candidates are required to complete a 5 km
run within 24 minutes. At the starting point of the race track, two RFID-
enabled mats were placed. These mats were equipped with sensor devices
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that automatically detect and record the time when a candidate steps on
them. Each candidate wears two RFID chips attached to their feet. As they
begin their run, the system logs the exact start time on the server. The total
time taken to complete the 5 km race will be calculated with the chip
attached to each candidate.
15. The running track of the ground measured 384.61 meters per
lap. It was verified and certified by the Recruitment Board. Further, 13 laps
were required to complete the 5-kilometer distance in 24 minutes, which
was mandated to pass the PET. Hence, the candidates were released on to
the track one after another, allowing the system to record each individual's
performance separately. The RFID system ensures accurate timing based on
each candidate's pace, stamina, and ability. He also produced the Indian
Meteorological Department Report from 17.08.2025, to 23.09.2025, and,
accordingly, there was no issue with the height measurement. He also
produced the videograph of the PET conducted from 20.08.2025 to
03.09.2025. It was conducted in two grounds in the same campus. The first
ground was used from 20.08.2025 to 22.08.2025, and the second ground
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was used from 20.08.2025 to 03.09.2025. Therefore, the contention of the
learned counsel for the petitioner that the size of each lap of the ground was
400 meters and as such, 13 laps come around 5,200 meters cannot be
accepted, since, each lap measures only about 384.61 meters.
16. Though it was rainy prior to the PET, the track was filled with
M-sand, and there was absolutely no slipperiness. In fact, only the
petitioners were not qualified for the PET, while 12,670 candidates qualified
in the PET and were subjected to medical examination. Therefore, those
who lacked stamina and ability could not complete 13 laps within the
stipulated time. If the petitioners are permitted to re-race, it would amount
to opening Pandora's box, and every candidate who failed to complete the
race within the stipulated time would approach this Court.
17. The learned Deputy Solicitor General of India further submits
that the Revised Guidelines for Recruitment Medical Examination are only
applicable for medical examination. As per the medical examination
process, after qualifying in the PET and PST, the medical examination will
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be conducted. During the medical examination, fractions in respect of
height and weight can be rounded off. As per the notification issued by the
respondents, there is absolutely no relaxation to round off the cm. The
physical standards fixed for males are 170 cm and for females are 157 cm. If
the candidates fail to satisfy this height requirement, they may not be
eligible for medical examination. Therefore, candidates are not allowed any
relaxation in the height except for reserved categories. Hence, the Revised
Guidelines for Recruitment Medical Examination are applicable only for
medical examination.
18. The learned Deputy Solicitor General of India has also
explained that the weight should be proportionate to the height and age as
per the medical records. While calculating the height and weight, if the
candidates are measured with fractions in their height as well as weight, it
can be rounded off. Therefore, guideline 2(d) is applicable only for medical
examination. Those who qualify in the PST/PET will be subjected to
medical examination. During the medical examination, if their weight and
height are not proportionate to each other, the fraction will be rounded off.
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Therefore, the contention of the petitioner that the fraction to be rounded off
cannot be countenanced. Further, it was not brought to the notice of the
Division Bench of the Hon'ble Delhi High Court and as such, it was held
that the guideline 2(d) of the General Instructions for the Recruitment Board
is not applicable for the PST & PET and it is only applicable for medical
examination.
19. All the petitioners were issued PST/PET rejection slips since
they were not qualified in the race and height. After qualifying in the CBE,
they were subjected to the PST and PET. Though during the PET, there was
no rain, on the previous day, there was heavy rain in Avadi. Therefore, the
entire ground was filled with water. After draining the water, the running
track was filled with M-sand to conduct the PET. On seeing the videograph
produced by the petitioners as well as the respondents, it clearly shows that
there was water stagnation on the running track itself.
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20. Though the running track was filled with M-sand, there was
slipperiness and mud. At a time, if 50 or 100 candidates were directed to
run, there will be pushing and pulling of each other, and there will be
clashes due to the slippery and wet ground. Therefore, they had to run one
by one, and as such, the race was not conducted on a standard ground. As
per the guidelines, Clause 6.4(xvii), the respondents must ensure to provide
a suitable ground for the race. On seeing the videograph, it reveals that the
ground in which the PET was conducted was not suitable for the race, since
there was rain due to which there was water stagnation. Therefore, the
petitioners who failed to complete the race of 5000 meters within the
stipulated time can be given one more opportunity.
21. Insofar as the PST is concerned, on perusal of the records
produced by the petitioners, it is revealed that some of the petitioners who
had participated in the recruitment for the very same post had their height
measured and were qualified in the PET. Further, now their height is not
qualified. Even according to the respondents, during the last recruitment
process, the height was measured manually. This time, digital equipment
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was used to measure the height of the candidates. Therefore, there is a
difference. Though the PST rejection slip provides for an appeal before the
Appellate Authority on the same day, the appeals made by the petitioners
were not considered by the respondents. Therefore, the petitioners who were
not qualified in the PST may also be given one more opportunity for PST.
22. In view of the above, the impugned PST and PET rejection
slips cannot be sustained and are liable to be quashed. Accordingly, the
impugned orders in these writ petitions are hereby quashed, and this Court
issues the following directions:-
(i) The respondents are directed to conduct a fresh PST and PET
for the male petitioners who had completed 13 laps in the PET conducted
from 20.08.2025 to 03.09.2025.
(ii) The respondents are directed to conduct a fresh PST and PET
for female petitioners who completed 4 laps in the PET from 20.08.2025 to
03.09.2025.
(iii) The respondents are directed to conduct a fresh PST for the
petitioners who challenged the PST rejection slip alone.
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(iv) It is made clear that the petitioners who had not completed 13
laps in the male category and 4 laps in the female category are not eligible
for a fresh PET for the post of Constable (GD) in the Central Armed Police
Forces (CAPFs) and SSF, Rifleman (GD) in Assam Rifles, and Sepoy in the
Narcotics Control Bureau - Examination 2025.
(v) It is also made clear that the fresh PST and PET shall be
conducted after completion of the rainy season, following the guidelines,
and the respondents must ensure to provide suitable grounds for the race.
(vi) The respondents shall conduct the PST with approved digital
machinery to measure the correct height of the petitioners.
(vii) It is made clear that the respondents are directed to verify
those who were issued PST/PET rejection slips with their records, and only
those who challenged the rejection slip before this Court are permitted to go
for a fresh PST/PET.
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21. In the result, these Writ Petitions are allowed as indicated
above. Consequently, the connected Miscellaneous Petitions are closed. No
costs.
28.10.2025
Index:Yes/No
Speaking Order/Yes/No
Neutral Citation/Yes/No
kv
Note: Registry is directed to incorporate cause title for
all the cases and issue order copy.
To
1. The Under Secretary for Government of India,
Staff Selection Commission Ministry of Personnel,
Public Grievances and Pensions Department and
Personnel and Training,
Block No.12, CGO Complex,
Lodhi Road,
New Delhi – 110 003.
2. Regional Director (Southern Region),
Staff Selection Commission,
2nd Floor, EVK Sampath Building,
DPI Campus, College Road,
Chennai, Tamil Nadu – 600 006.
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W.P.No.33420 of 2025 etc. batch
3. The Directorate General
CRPF (Recruitment Branch)
East Block 07, Level – 4
Sector 01, R.K.Puram,
New Delhi – 110 066.
4. Second in Command
(IRLA-6065) RANGE: BLR, CRPF
Presiding Officer of PET/PST Board,
Rectt of CT/GF – 2025
In CAPFS, SSF and Assam Rifles
Rectt. Centre: GC, CRPF, Avadi.
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W.P.No.33420 of 2025 etc. batch
G.K.ILANTHIRAIYAN, J.
kv
W.P.No.33420 of 2025 etc. batch
28.10.2025
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