Mere Abnormal Liver Function Test Is Not a Ground for Disqualification: Delhi High Court Orders Fresh Medical Board for Agniveervayu Aspirant

"Unless the liver condition falls within specific disqualifying categories, medical rejection is unjustified" – In a decisive interpretation of the medical eligibility standards for recruitment into the Indian Air Force, the Delhi High Court held that a candidate cannot be medically disqualified solely on the basis of abnormal liver function test (LFT), unless it is proven that the liver abnormality falls under one of the specified pathological conditions listed in Clause 83(b) of the Manual of Medical Examinations and Medical Boards, issued by the Chief of the Air Staff.

Petitioner challenged his medical disqualification from the Agniveervayu Intake 01/2026 selection process. The Court, comprising Justice C. Hari Shankar and Justice Om Prakash Shukla, ordered that the petitioner be re-examined by a Medical Board at the Army Research & Referral (R&R) Hospital, which must include a competent hepatologist or gastroenterologist. The outcome of this examination will determine whether the petitioner may proceed in the recruitment process.

Court Interprets Clause 83(b): “Exhaustive List of Disqualifying Liver Conditions”

The core legal question before the Court was whether the Indian Air Force could reject a candidate purely based on abnormal liver function test results, without a finding of any definitive liver disease or disorder that is listed under the disqualifying conditions in the Manual.

The Court examined Clause 83 of the Manual, which lays down both qualifying and disqualifying standards for liver health:

“(b) UNFIT –
(i) Fatty liver – Grade 2/3 and Grade 1 with abnormal LFTs
(ii) Space Occupying Lesion (SOL) in the liver
(iii) Portal vein thrombosis
(iv) Evidence of portal hypertension
(v) Hepatic calcification
(vi) Hepatomegaly more than 15 cm, if clinically also liver is palpable”

Justice C. Hari Shankar, delivering the oral judgment, held that this list is exhaustive, and unless the candidate is found to suffer from one or more of these six conditions, mere abnormal LFTs are not sufficient to render a candidate unfit.

Para 3.5.3 Merely Procedural, Does Not Override Substantive Disqualifications

The respondents, represented by Mr. Dhananjai Rana, CGSC, argued that Para 3.5.3 of the Manual provides the basis for medical disqualification in liver-related cases. However, the Court categorically rejected this contention, stating:

“Para 3.5.3 merely sets out procedures to be followed and does not set out the standards on the basis of which the liver function of the candidate is to be assessed to determine his eligibility.”

The Court drew a clear distinction between procedural safeguards under Para 3.5.3 (relating to candidates with past history of jaundice or hepatitis) and the substantive disqualifying criteria under Clause 83(b), which directly govern recruitment eligibility.

The judgment emphasized that unless a candidate's condition squarely fits within one of the medically recognized disorders under Clause 83(b), a deviation from the guidelines cannot be sustained in law.

Court Cites Its Earlier Ruling in Thakur Sarthk Ajeet Singh, Emphasizes Consistency

The petitioner, represented by advocates Mr. Tushar Swami, Mr. Prakhar Singh Sengar and Mr. Shantanu Shukla, relied on a recent ruling of the Delhi High Court in Thakur Sarthk Ajeet Singh v. Union of India (judgment dated 21 August 2025), where a similar medical disqualification had been overturned on the basis of the same Clause 83. The Court acknowledged this decision and held that the interpretation adopted in Thakur Sarthk was binding and had to be consistently applied.

Justice Hari Shankar reaffirmed:

“Clearly, mere abnormal liver function tests do not constitute a basis to disqualify a candidate, unless the case falls within one of the six categories below clause 83(b).”

The CGSC for the respondents was unable to dispute this legal position, and hence the Court proceeded to issue directions for a fresh examination.

Re-examination Ordered at R&R Hospital with Specialist Involvement

Taking a corrective approach to administrative error, the Court directed that the Army Research and Referral Hospital constitute a Medical Board to reassess the petitioner’s medical fitness. Importantly, the Board must include a competent hepatologist or gastroenterologist to ascertain whether the petitioner falls within any of the disqualifying liver conditions in Clause 83(b).

The Court fixed the date of appearance for the petitioner before the Medical Superintendent, R&R Hospital, as 5 November 2025 at 10:30 AM, and recorded the petitioner’s undertaking to abide by the outcome of the evaluation.

It clarified that if the Board finds the petitioner medically fit, his recruitment process shall proceed accordingly, and any prior rejection would be rendered invalid.

Rejection Based on Mere Abnormal LFTs Is Ultra Vires Medical Standards

Summing up, the Court held that the rejection of a candidate without clinical diagnosis of a listed liver disorder is not sustainable under the Indian Air Force’s own medical guidelines. The disqualification, based merely on liver enzyme readings or biochemical markers, without clinical corroboration of Grade-II/III fatty liver, portal hypertension, or other enumerated conditions, violates the uniformity and objectivity expected in military recruitment.

The writ petition was accordingly disposed of with directions for re-evaluation, ensuring that due process and medical fairness prevail in the selection of personnel under the Agniveervayu recruitment scheme.

Date of Decision: 31 October 2025