The Telangana High Court has upheld the termination of a Central Reserve Police Force (CRPF) constable who was diagnosed with depression and declared medically unfit for basic training and service. The Court found that the constable had been afforded ample opportunity at every stage of the proceedings and was subjected to repeated medical evaluations before the Review Medical Board recommended termination.
The Court observed that the Review Medical Board had taken into account the inherent stress of CRPF basic training and the high risk arising from easy access to firearms, which posed a danger not only to the petitioner but also to others. This consideration formed a key part of the Board’s recommendation to terminate the constable’s services.
The petitioner was appointed as a constable in the CRPF in April 2021 and sent to the Recruit Training Centre at Suratgarh for basic training. Within six weeks of commencing training, he was admitted to the ATC Hospital at Suratgarh with complaints of excessive negative thoughts, restlessness, and mood swings. He underwent treatment at various hospitals and was prescribed anti-depressants and benzodiazepines. Following this, he was relegated from basic training and returned to the CRPF Group Centre at Hyderabad.
A psychiatric evaluation conducted at the CRPF Composite Hospital in Hyderabad in June 2021 found that he continued to experience negative thoughts and diagnosed him with ‘Mixed Anxiety and Depression’. He was provisionally declared unfit for basic training and advised to continue medication. A subsequent review in August 2021 by a psychiatrist confirmed that he remained unfit for basic training and advised the continuation of medication.
The petitioner contended that he had sought leave during training to visit his parents, which was refused, and that the authorities suspected depression due to the denied leave, leading to his psychiatric examination. He claimed that a psychiatric test conducted in March 2022 showed him as normal. Despite this, he was transferred to Hyderabad and allegedly assigned menial tasks such as watering plants, sweeping, and mixing cement and sand. He further alleged that on May 10, 2022, he was handed his termination letter at around 8 PM and made to leave the CRPF campus without being assigned any reasons or issued a show-cause notice, which he argued violated the principles of natural justice.
The petitioner approached the Government Hospital for Mental Care at Erragadda seeking another psychiatric examination but was informed that such an examination could be conducted only on a reference from the CRPF. His requests to the CRPF authorities for such a reference were not accepted, as he contended.
The CRPF disputed the petitioner’s account, stating that after his earlier examinations, approval was obtained for a Review Medical Examination at the CRPF Composite Hospital in New Delhi. A Review Medical Board, comprising medical officers including psychiatrists, was constituted. When the petitioner reported for examination on March 4, 2022, he stated that he had not taken medication for the preceding 40 days and denied having fresh complaints. He initially appeared normal and was admitted for observation without medication. However, according to the CRPF, he subsequently developed uneasiness and discomfort, leading to his referral to Ram Manohar Lohia Hospital in New Delhi for further evaluation.
Justice Pulla Karthik held that the constable had been afforded ample opportunity at every stage of the proceedings and had been subjected to repeated medical evaluations. The Court found no fault with the CRPF’s decision to terminate his services under Rule 6 of the Central Civil Services (Temporary Service) Rules, 1965. The Court emphasized that the Review Medical Board had duly considered the inherent stress of CRPF training and the risk posed by easy access to firearms before recommending termination.
The Court concluded that there was no violation of procedural fairness or natural justice in the termination process. The petitioner had been given multiple opportunities to present his case and undergo medical review. The decision to terminate was based on a thorough and documented medical assessment that appropriately considered both the petitioner’s mental health condition and the operational risks associated with his role in a paramilitary force equipped with firearms.