Supreme Court Grants Relief to UPSC Aspirant for Missed Medical Re-Examination

The Supreme Court of India recently ruled in favor of Rakshit Shivam Prakash, a UPSC aspirant who was denied appointment to the Civil Services due to his failure to appear for a medical re-examination in 2015. The Court granted him a fresh opportunity for a medical test, invoking its powers under Article 142 of the Constitution to ensure complete justice.

Background of the Case

The petitioner, Rakshit Shivam Prakash, applied for the UPSC Civil Services Examination (CSE) 2014. He successfully cleared the Prelims, Mains, and Interview stages. However, during his medical examination conducted on April 29, 2015, he was declared ‘temporarily unfit’ due to his Body Mass Index (BMI) being 31.75, exceeding the prescribed standard of 30.

The petitioner was entitled to a re-medical examination, which was scheduled for July 14, 2015. However, before this date, the final result of the UPSC examination was published on July 4, 2015, and his name was not included. Believing that he had failed to make the final cut, he did not appear for the re-medical test.

The Turn of Events

On January 19, 2016, the UPSC released a Reserve List of 126 candidates to fill remaining posts. The petitioner was ranked 93rd in this list. However, despite his rank, he was not allocated a service, whereas candidates ranked below him, up to 97th rank, were allotted services.

Realizing that his medical status was the reason for his exclusion, the petitioner approached the Central Administrative Tribunal (CAT), Patna, seeking directions to be considered for appointment. However, his plea was dismissed, with the Tribunal relying on its earlier decision in the case of K. Rajashekhara Reddy, who had also failed to qualify in the medical test.

Legal Battle and High Court Proceedings

Aggrieved by the CAT’s decision, the petitioner filed a writ petition before the Patna High Court. However, during the pendency of his case, the High Court of Telangana ruled in favor of K. Rajashekhara Reddy on April 6, 2021, granting him relief.

The Union of India challenged this decision in a Special Leave Petition before the Supreme Court. However, the apex court, through its order dated June 14, 2022, directed a re-medical examination for Reddy, following which he was found fit for service. The Court then directed his appointment with all consequential benefits except back wages.

Upon learning of this development, the petitioner withdrew his writ petition from the Patna High Court and submitted a representation to the Department of Personnel and Training (DoPT), seeking similar relief.

Government’s Stand

The DoPT rejected his representation, stating that the Supreme Court’s ruling in Reddy’s case had upheld the government’s position that there was a time limit for medical re-examinations. Since the Civil Services Examination Rules, 2014, confirmed him as ‘unfit for all services’, his case was closed.

Supreme Court’s Observations

The Supreme Court, while hearing the petition, noted the following:

The petitioner had legitimate reasons to assume that he was no longer in contention when the final result was published before his re-medical test.
Other candidates who had appeared in the reserve list of January 19, 2016, and were ranked below him had been allocated services.
In a similar case, K. Rajashekhara Reddy was granted relief by the Supreme Court, where he was allowed a fresh medical test and subsequently appointed.
The petitioner was 35 years old and had exhausted all his attempts for the Civil Services Examination, just like Reddy.

Final Judgment

On August 2, 2024, the Supreme Court ruled:

The petitioner shall be given a fresh medical examination within four weeks.
If found medically fit, he shall be appointed to a suitable service.
He will not be entitled to seniority in the 2014 batch or claim back wages.
His service commencement shall be from the date of actual appointment.

Implications of the Judgment

This ruling has significant legal and administrative implications:

Judicial Intervention in UPSC Selections: The judgment reaffirms that courts can intervene in exceptional cases to correct procedural unfairness.
Impact on Re-Medical Exam Policies: The decision questions the rigidity of the government’s time limits for medical re-examinations.
Fair Treatment for Candidates: The ruling ensures that candidates who are similarly placed are treated equitably in government recruitment.
Non-Precedential Nature: The Court made it clear that this was an exceptional case and should not be treated as a precedent.

Comparison with Similar Cases

The Supreme Court has previously ruled on similar recruitment disputes:

Union of India vs. Ashok Kumar (2021): The Court held that procedural fairness must be upheld in government appointments.
Rameshwar Prasad vs. Union of India (2019): Candidates denied appointment due to administrative lapses were granted relief.
K. Rajashekhara Reddy vs. Union of India (2022): Similar to the present case, relief was granted for a missed medical examination.

Conclusion

The Supreme Court’s decision in Rakshit Shivam Prakash vs. Union of India highlights the judiciary’s role in rectifying administrative unfairness. By invoking Article 142, the Court ensured justice for the petitioner while balancing administrative constraints. However, the Court also clarified that this judgment should not be used as a precedent in future cases.

Petitioner Name: Rakshit Shivam Prakash.
Respondent Name: Union of India and Anr..
Judgment By: Justice Pamidighantam Sri Narasimha, Justice Pankaj Mithal.
Place Of Incident: New Delhi.
Judgment Date: 02-08-2024.

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