High Court reaffirms strict adherence to prescribed physical standards under Odisha Forest Service Recruitment Rules, 2013, and quashes extraneous blood pressure test as illegal and arbitrary
Summary
| Category | Data |
|---|---|
| Case Name | WP(C)/20102/2025 of DEBASHIS DASH Vs STATE OF ODISHA |
| CNR | ODHC010504952025 |
| Decision Date | 18-08-2025 |
| Disposal Nature | Disposed Off |
| Judgment Author | Mr. Justice Aditya Kumar Mohapatra |
| Court | Orissa High Court |
| Bench | Single Judge |
| Precedent Value | Binding on Orissa High Court and recruiting authorities under OPSC |
| Overrules / Affirms | Affirms strict application of Rule-8; overrules blood pressure disqualification practice |
| Type of Law | Administrative law – Recruitment Rules |
| Questions of Law | Whether disqualification based solely on a blood pressure test, absent from the advertisement and rules, is legal |
| Ratio Decidendi |
The Court held that Clause 5 of the recruitment advertisement and Rule 8 of the 2013 Rules exclusively govern the physical standard and endurance tests, with no provision for blood pressure monitoring. As Rule 11 does not list blood pressure as a disqualification ground, eliminating candidates on that basis was extraneous to the prescribed criteria and hence arbitrary. The disqualification orders were quashed, and petitioners were directed to undergo the walking test upon furnishing a normal blood pressure certificate and undertaking. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | Recruiting authorities under OPSC and subordinate courts in Odisha |
What’s New / What Lawyers Should Note
- Clarifies that any elimination criterion must be expressly provided in the advertisement and Recruitment Rules, 2013.
- Blood pressure measurement, not specified in Clause 5 or Rule 8, cannot form a ground for disqualification.
- Candidates disqualified on unauthorized grounds are entitled to a retest upon furnishing a medical certificate and undertaking.
- Courts will intervene to quash procedures that deviate from the prescribed recruitment process, even for health and safety considerations.
Summary of Legal Reasoning
- Governing provisions: Advertisement Clause 5 and Rule 8 of the 2013 Rules prescribe height, chest measurements, and walking distances; no blood pressure test.
- Recruitment sequence: Written test → physical standard/endurance walking test → viva voce; BP monitoring is not authorized.
- Disqualification rules: Rule 11 lists permissible grounds; blood pressure readings are absent.
- Arbitrariness: Using a faulty digital instrument for BP monitoring and disqualifying candidates violates the recruitment conditions.
- Relief granted: Disqualification quashed; candidates to retake walking test within four weeks on submitting a physician’s certificate and undertaking.
Arguments by the Parties
Petitioners
- Successfully cleared the written examination and met physical standards per the advertisement and Rule 8.
- Disqualified solely on the basis of faulty digital blood pressure readings.
- No mention of blood pressure measurement in the advertisement or Rules 2013; test was extraneous and arbitrary.
- Denied opportunity to be heard before disqualification.
Opposite Parties (OPSC & State)
- Recruitment conducted under Rules 2013 and advertised conditions.
- BP monitoring introduced after a candidate fainted, in the interest of candidate safety.
- Health check is in larger public interest and not arbitrary.
Factual Background
In May 2023, OPSC advertised 131 Forest Ranger and 45 Assistant Conservator of Forests posts under the Odisha Forest Service Recruitment Rules, 2013. Petitioners cleared the written examination held from 18 to 28 August 2024. Physical endurance walking tests were scheduled from 14 to 20 July 2025. Before the walk, candidates’ blood pressure was measured using a digital instrument, and several petitioners were disqualified based on those readings. Aggrieved, they filed writ petitions challenging the BP test as unauthorized.
Statutory Analysis
- Rule 8 (Physical Standard): Specifies height, chest expansion, and walking test distances (males 25 km/4 hrs, females 16 km/4 hrs); omits blood pressure monitoring.
- Rule 11 (Disqualifications): Enumerates grounds for disqualification; no reference to blood pressure.
- Advertisement Clause 5: Mirrors Rule 8; no BP requirement.
- Conclusion: Any disqualification on the basis of blood pressure is outside the scope of the recruitment rules and advertisement.
Alert Indicators
- ✔ Precedent Followed