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
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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
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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
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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 4/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) 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. 5/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch
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 6/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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 7/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) 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 8/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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 9/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) 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 10/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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 11/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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 12/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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 13/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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 14/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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. 15/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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. 16/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch
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 17/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch 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. 18/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch
(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.
20/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) 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.
21/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm ) W.P.No.33420 of 2025 etc. batch G.K.ILANTHIRAIYAN, J.
kv W.P.No.33420 of 2025 etc. batch 28.10.2025 22/22 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/11/2025 07:46:40 pm )