Court Holds That Disqualifying Candidates Solely on Blood Pressure Readings, Absent Mention in Rule 8 or the Advertisement, Is Arbitrary and Illegal
Summary
| Category | Data |
|---|---|
| Case Name | WP(C) No. 20355 of 2025 of Leeman Acharya Vs State of Odisha |
| CNR | ODHC010514242025 |
| Decision Date | 18-08-2025 |
| Disposal Nature | Disposed of |
| Judgment Author | Mr. Justice Aditya Kumar Mohapatra |
| Court | Orissa High Court |
| Bench | Single Judge |
| Questions of Law | Whether disqualification of candidates based solely on blood pressure measurement, not prescribed in Rule 8 of the Odisha Forest Service Recruitment Rules, 2013 or in the advertisement, is valid or illegal? |
| Ratio Decidendi | The Court held that the physical standard and endurance criteria under Rule 8 and the corresponding advertisement clause did not include any requirement for measuring blood pressure. Disqualification based solely on blood pressure readings constitutes a deviation from the advertised criteria and the statutory rules, rendering the action arbitrary and illegal. The disqualifications were quashed, and petitioners were directed to undergo the endurance test subject to furnishing a normal blood pressure certificate from a registered medical practitioner. |
| Logic / Jurisprudence / Authorities Relied Upon | Analysis of Clause 5 of the recruitment advertisement and Rule 8 of the Odisha Forest Service Recruitment Rules, 2013—highlighting the absence of any blood pressure test requirement; interpretation of the sequential stages of recruitment (written, physical standard & endurance, viva voce) and the disqualification criteria under Rule 8(iii) and Rule 11. |
| Facts as Summarised by the Court | OPSC advertised recruitment for Forest Ranger and Assistant Conservator of Forests posts; petitioners cleared the written test held in August 2024; during the physical endurance (walking) test in July 2025, digital blood pressure readings led to their disqualification; petitioners alleged the test was not part of the advertised or statutory criteria; OPSC and State defended it on safety grounds; High Court quashed the disqualifications and directed a fresh walking test. |
What’s New / What Lawyers Should Note
- Clarifies that the physical standard and endurance criteria under Rule 8 of the Odisha Forest Service Recruitment Rules, 2013—and the matching advertisement clause—do not authorize separate blood pressure measurements as a ground for disqualification.
- Establishes that any elimination test must strictly adhere to the criteria advertised and prescribed by statute; deviation will be deemed arbitrary and unlawful.
- Confirms that courts may condition relief on candidates furnishing a medical certificate of normal blood pressure, thereby balancing procedural fairness with candidate safety.
Summary of Legal Reasoning
- The Court scrutinised Clause 5 of the recruitment advertisement and Rule 8 of the 2013 Rules, noting both prescribe only height, chest measurements, and a walking endurance test—without any blood pressure requirement.
- It outlined the recruitment process: written exam → physical standard & endurance test → viva voce.
- It observed that disqualification should follow only failure in the tests expressly prescribed.
- Rule 11’s disqualification provisions were examined; no blood pressure criterion appears.
- The introduction of a blood pressure test was held extraneous to the statutory scheme and thus arbitrary.
- The Court quashed the disqualifications and directed a fresh walking test, subject to a normal blood pressure certificate from a registered medical practitioner.
Arguments by the Parties
Petitioners
- Clause 5 of the advertisement and Rule 8 do not mention any blood pressure test as part of physical standards or endurance criteria.
- Disqualification based on digital blood pressure readings (allegedly faulty instrument) is extraneous, arbitrary, and violates Article 14, 16, and 21.
- No prior opportunity was given to challenge the measurement before disqualification.
Odisha Public Service Commission (OPSC)
- Physical endurance tests are conducted under its supervision; safety concerns arose after a candidate fainted during the walking test.
- Blood pressure measurement was introduced to protect candidate welfare; only those with normal readings were permitted to continue.
- Such safety-driven measures, in the public interest, cannot be deemed illegal or arbitrary.
State–Opposite Parties
- Supported OPSC’s safety-based approach, monitored by medical and forestry experts.
- Argued the measure was necessary after the fainting incident and did not contravene any statutory rule or advertised term.
Factual Background
In May 2023, the Odisha Public Service Commission advertised 131 Forest Ranger and 45 Assistant Conservator of Forests vacancies under the Odisha Forest Service Cadre. Candidates, including the petitioners, cleared the written examination held from 18–28 August 2024. A physical standard and endurance (walking) test was scheduled for 14–20 July 2025. Before the walking test, a digital blood pressure measurement was introduced, leading to the petitioners’ disqualification on allegedly faulty readings. They challenged this disqualification as beyond the scope of the advertised and statutory criteria.
Statutory Analysis
- Rule 8 of the Odisha Forest Service Recruitment Rules, 2013 mandates:
- Height and chest measurement standards.
- Physical endurance test of walking: 25 km in 4 hours (male), 16 km in 4 hours (female).
- No provision for blood pressure monitoring.
- Clause 5 of the recruitment advertisement replicates Rule 8 without any mention of blood pressure assessment.
- Rule 11 outlines general disqualification grounds but omits any reference to blood pressure criteria.