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Supreme Court Orders Fresh Medical Test for Civil Services Candidate Discarded in 2014 Due to Obesity

Rakshit Shivam Prakash, who successfully cleared the civil services exam in 2014, was denied employment based on his Body Mass Index (BMI), which was recorded at 31.75
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In a landmark decision, the Supreme Court of India has ordered the Union Public Service Commission (UPSC) to conduct a fresh medical examination for Rakshit Shivam Prakash, a candidate who was declared “temporarily unfit” for civil service in 2014 due to obesity. The decision comes nearly a decade after Prakash was denied a position despite ranking 93rd in the highly competitive civil services examination.

Background of the Case

Rakshit Shivam Prakash, who successfully cleared the civil services exam in 2014, was denied employment based on his Body Mass Index (BMI), which was recorded at 31.75. This figure exceeded the prescribed standard BMI of 30, leading to his classification as “temporarily unfit” for service. The UPSC scheduled a second medical test for July 14, 2015, but Prakash was unable to attend, further complicating his path to becoming a civil servant.

Supreme Court’s Intervention

In an effort to deliver justice, the Supreme Court invoked its special powers under Article 142 of the Indian Constitution. This article allows the court to issue decrees or orders necessary for providing complete justice in any case or matter pending before it. The bench, comprising Justices P S Narasimha and Pankaj Mithal, directed the UPSC and other relevant authorities, including the Department of Personnel and Training, to reschedule the medical examination initially planned for July 2015.

The court’s decision was guided by the unique circumstances of the case, with Justice Narasimha stating, “Having considered the facts and circumstances of the case, we consider it appropriate to grant limited relief. This will be to direct the respondents to reschedule the re-medical test that was to be conducted on July 14, 2015, which the petitioner unfortunately missed.”

Limitations of the Court’s Order

While the Supreme Court granted Prakash the opportunity for a new medical test, it denied his plea for automatic service allocation and the consequential benefits of being treated on par with other candidates from the 2014 batch. The bench clarified that even if Prakash passes the medical re-examination, he will not be eligible for appointment in the 2014 batch or for any seniority benefits associated with it.

In its judgment, the court stated, “At the outset, we reject the prayer made by the petitioner for allocation of service and consequential benefits against Civil Services Examination, 2014. Considering the fact that the original re-medical examination was to happen in 2015 and almost a decade has passed by, we direct that in the event the petitioner qualifies in the medical re-examination, he shall neither claim appointment in the 2014 batch nor will he be entitled to seniority in the batch in which he could be appointed.”

Broader Implications

This decision by the Supreme Court highlights the complexities and challenges faced by candidates in the civil services selection process, especially regarding health and fitness standards. It also underscores the judiciary’s role in ensuring fairness and justice, particularly in cases where procedural or administrative decisions may have led to unintended consequences.

For Rakshit Shivam Prakash, this ruling offers a long-awaited chance to pursue his aspirations in public service, albeit with certain limitations. The case also raises questions about the balance between maintaining health standards and providing equitable opportunities for all candidates in one of India’s most prestigious career paths.

As Prakash prepares for his re-evaluation, the decision serves as a reminder of the evolving standards and expectations within the Indian civil services landscape.


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