Disability Reservation Subject to Notified Functional Requirements:
A Detailed Commentary on Sajil Kumar v. State of H.P. & Others, CWP No. 4525 of 2023

Court: High Court of Himachal Pradesh, Shimla (Single Bench)
Coram: Hon'ble Mr. Justice Sandeep Sharma
Date of Decision: 07 November 2025
Citation: 2025 HHC 37386-DB
Parties: Sajil Kumar (Petitioner) v. State of Himachal Pradesh & Others (Respondents)

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I. Introduction

The judgment in Sajil Kumar v. State of H.P. & Others addresses a sensitive and increasingly important intersection of disability rights and public employment, particularly in posts where physical mobility and functional capacity are considered essential. At its core, the case raises a pointed question:

Does the mere possession of a statutory disability certificate and eligibility under a reserved category entitle a disabled candidate to appointment, irrespective of post-specific physical requirements notified by the State under the disability law?

The petitioner, Sajil Kumar, a person with 50% locomotor disability, belonging to the Scheduled Caste (SC) category with Persons with Disabilities (PWD) reservation, sought appointment as a Pharmacist (Allopathy) on a contract basis in the Health Department of Himachal Pradesh. Although he possessed the requisite educational qualifications (B. Pharmacy, 2005) and a disability certificate, the State declined to appoint him on the ground that he did not meet the prescribed physical requirements of the post—specifically, proper standing and walking.

The case sits at the intersection of:

• Reservations for persons with disabilities in public employment;
• The concept of functional suitability for identified posts;
• The scope of employer discretion when disability certificates make appointment “subject to employer’s conditions”;
• The doctrine of reasonable accommodation under the Rights of Persons with Disabilities Act, 2016 (“RPwD Act, 2016”).

Against this backdrop, the High Court had to decide whether the State’s refusal to appoint the petitioner as a Pharmacist was arbitrary or illegal, or whether it was justified in view of the notifications identifying the post and stipulating its physical requirements, and the opinion of expert medical bodies.

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II. Summary of the Judgment

1. Reliefs Sought

The petitioner prayed for:

• A writ of certiorari to quash the selection/appointment of respondent no. 4 (another candidate appointed as Pharmacist under the PWD quota);
• A writ of mandamus directing the respondents to select and appoint him as Pharmacist (Allopathy) on a contract basis, on batch-wise seniority under the SC (PWD) category.

2. Factual Background in Brief

• In August 2020, the Health Department advertised 17 posts of Pharmacist (Allopathy) for PWD candidates, including posts for the “Ortho Impaired” category. The petitioner applied and attended counselling, but no result was declared.
• In 2022, the recruitment was resumed on a batch-wise contract basis for PWD candidates. The petitioner’s name was sponsored by the Employment Exchange, and he attended counselling.
• He was referred to the State Medical Board (DDU Zonal Hospital, Shimla), which issued a certificate recording 50% permanent locomotor disability (Annexure P-5). However, the certificate explicitly stated that appointment would be subject to conditions imposed by the employer.
• On 07.06.2023, the Department filled 11 pharmacist posts (3 for hearing impaired and 8 for orthopedically impaired candidates), including appointment of respondent no. 4. The petitioner was denied appointment on the ground that he was not fit for the job in terms of physical requirements—particularly, standing and walking.
• Six posts meant for hearing impaired candidates remained unfilled for want of eligible candidates.

3. Procedural Trajectory and Medical Evaluation

During the writ proceedings, the High Court did not immediately decide on merits. Instead, it adopted an incremental, fact-finding approach:

• On 15.12.2023, the Court ordered a fresh examination by a competent Medical Board, asking it to opine whether the petitioner was fit to perform the duties of a Pharmacist.
• The petitioner was examined multiple times; he underwent a neuro-psychiatric assessment at PGIMER, Chandigarh and was later referred to IGMC/AIMSS, Shimla for neurological assessment.
• On 05.05.2025, Dr. Sudhir Sharma, Professor & Head, Department of Neurology, Atal Institute of Medical Super Specialties, Shimla, opined that:
  “He needs assistance in his activities of daily living due to left side weakness but has normal cognitive abilities and can perform essential duties of a pharmacist with some accommodation and assistance.”
• The Director of Health Services then constituted a departmental committee to assess, in light of this medical opinion and the applicable Government Notifications (including the one dated 26/27.09.2022), whether the petitioner could be considered fit for appointment to the post of Pharmacist (now styled as Pharmacy Officer).
• On 07.07.2025, the Committee concluded that, considering:
  • his 50% locomotor disability, left homonymous hemianopia, left hemiparesis and right temporal craniectomy;
  • the notified physical requirements for a Pharmacist; and
  • the categories of disabilities identified as suitable for the post under the 26.09.2022 Notification,
  the petitioner did not fall within the “disabled persons suitable for the post” and therefore was not suitable for appointment.

4. Final Holding

The High Court dismissed the writ petition, holding that:

• The disability certificate, which recorded 50% disability, clearly mentioned that appointment was subject to the employer’s conditions. Hence, the employer was entitled to assess whether the petitioner’s functional abilities matched the notified physical requirements for the post.
• The State’s Notifications (2012 and especially 26/27.09.2022) validly identified:
  • the post of Pharmacist for reservation under the disability quota, and
  • the categories of disabilities and physical requirements (sitting, standing, walking, etc.) necessary for the post.
  These Notifications were not challenged in the present proceedings.
• The Medical Board and the departmental committee—both expert bodies—had found the petitioner unsuitable for the Pharmacist’s post, particularly because of his inability to meet the standing and walking requirements. Courts would not ordinarily interfere with such expert determinations when grounded in unchallenged statutory criteria.
• While disability matters must be handled with sensitivity, as emphasised by the Supreme Court in Syed Bashir-Ud-Din Qadri v. Nazir Ahmed Shah, sensitivity cannot override prescribed functional requirements for a post, especially when validly notified.
• The recent Supreme Court judgment in Recruitment of Visually Impaired in Judicial Services v. Registrar General, High Court of Madhya Pradesh (2025 SCC OnLine SC 481) did not assist the petitioner because:
  • that was a case where the rules themselves excluding visually impaired candidates from judicial service were under constitutional challenge, and
  • the nature of judicial work (primarily cognitive and not physically strenuous) is substantially different from the physically demanding duties attached to the post of Pharmacist.

Thus, the Court declined to quash the appointment of respondent no. 4, and refused to issue a mandamus directing appointment of the petitioner.

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III. Analysis of the Judgment

A. Core Legal Principle Emanating from the Case

The judgment establishes, in effect, the following key legal principle:

A person’s entitlement to reservation under the disability quota in public employment is necessarily subject to the post-specific physical requirements and categories of disabilities validly notified by the Government under the disability legislation. A disability certificate, even where it records a qualifying percentage of disability, does not automatically confer a right to appointment if the candidate is medically assessed as not meeting those notified functional requirements.

Equally important is the procedural corollary:

Where the statutory rules/notifications identifying posts and suitable disability categories are not themselves challenged, courts will ordinarily defer to the opinion of expert medical and departmental committees in determining whether a disabled candidate is functionally fit for a particular post.

B. Precedents and Authorities Discussed

1. Syed Bashir-Ud-Din Qadri v. Nazir Ahmed Shah, (2010) 3 SCC 603

The petitioner relied heavily on this Supreme Court decision. In that case, the Court emphasised that:

“… this case involves a beneficial piece of social legislation to enable persons with certain forms of disability to live a life of purpose and human dignity. This is a case which has to be handled with sensitivity and not with bureaucratic apathy…”

The Supreme Court in Syed Bashir-Ud-Din Qadri underscored:

• that disability laws are beneficial legislation and must be interpreted liberally in favour of persons with disabilities;
• that administrative decision-making must eschew rigid, mechanical application of rules and adopt a humane, empathetic outlook towards disabled candidates; and
• that the aim is not mere subsistence but a life of dignity and purposeful engagement with society.

Justice Sandeep Sharma acknowledges this principle, explicitly noting that cases involving disability:

“… are required to be handled with sensitivity and not with bureaucratic apathy …”

However, he distinguishes the case at hand on the ground that, despite the liberal ethos of the Supreme Court decision, the petitioner:

• did not challenge the Government’s Notification prescribing the physical requirements and eligible disability categories;
• was found by an expert Medical Board and a specialist departmental committee to be functionally unfit for the job of Pharmacist in light of those requirements.

Thus, while the Court pays respect to the Supreme Court’s directive on sensitivity, it ultimately prioritises the notified functional criteria and the opinion of expert bodies.

2. Recruitment of Visually Impaired in Judicial Services v. Registrar General, High Court of Madhya Pradesh
(2025 SCC OnLine SC 481)

This very recent Supreme Court judgment was cited by the petitioner at a later stage in the proceedings. It arose from a suo motu cognizance taken by the Supreme Court upon a letter from the mother of a visually impaired LL.B. graduate who was barred from competing for judicial services in Madhya Pradesh due to Rule 6A of the M.P. Judicial Services Rules, 1994.

The Supreme Court held that:

• Once a person with disability has been permitted to pursue a law degree, they cannot be per se excluded from being considered for judicial office;
• Blanket exclusion of visually impaired candidates from judicial service was unconstitutional and violated the principle of reasonable accommodation under the RPwD Act, 2016;
• Visually impaired judges could effectively discharge judicial functions with the assistance of court staff, assistive technologies, and accessible reading/writing facilities.

Justice Sharma expresses full agreement with the Supreme Court’s reasoning in principle, but distinguishes it on two major grounds:

1. Nature of Work: Judicial work is described as largely intellectual—reading, dictation, conducting court proceedings, and writing judgments—activities that, unlike a Pharmacist’s core functions, do not inherently require significant physical movement or physical exertion.
2. Challenge to Rules vs. Individual Claim: In the Supreme Court case, the very validity of the rules that excluded visually impaired candidates was under challenge. The Court examined and struck down those exclusionary rules as being contrary to the RPwD Act and the mandate of reasonable accommodation. In Sajil Kumar, by contrast:
   • The petitioner did not challenge the Notification dated 26/27.09.2022, which identifies the post of Pharmacist and prescribes specific physical requirements and disability categories.
   • The litigation was limited to demanding his own appointment, without attacking the framework that was applied to assess his suitability.

This distinction is doctrinally important because the High Court is effectively saying: If you wish to challenge exclusionary criteria themselves (e.g., the list of suitable disabilities for a post, or the physical requirements), you must directly attack those rules/notifications. A mere service dispute on non-selection, without such a challenge, cannot indirectly nullify the notification.

C. Legal Reasoning: Step-by-Step

1. Status and Effect of the Disability Certificate

The petitioner’s core assertion was that, having been certified with 50% locomotor disability under the PWD category, he was entitled to appointment against a reservation earmarked for persons with disabilities (especially as a Scheduled Caste candidate under the PWD quota).

However, the Court notes a crucial feature of the disability certificate dated 24.01.2023 (Annexure P-5):

The certificate records 50% permanent disability but explicitly states that appointment is “subject to the condition rested to the employer”.

Justice Sharma interprets this to mean:

• The certificate is not a blanket declaration of fitness for any and every post.
• Instead, it acknowledges that the employer retains the prerogative to judge whether, notwithstanding the disability, the candidate can fulfil the functional requirements of a particular job.

This is a significant interpretive move: the Court positions the disability certificate as establishing the quantum and nature of disability, but not as conclusively determining job-specific suitability. In effect, it separates:

• Medical certification of disability (percentage and type), from
• Administrative assessment of functional fitness for a given post.

2. Role of Government Notifications Identifying Posts and Physical Requirements

Two key notifications are central to the reasoning:

1. Notification dated 23.03.2012
   Issued under the earlier Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995, this notification:
   • Identified posts in the Health and Family Welfare Department as being reserved for disabled persons (3% at that time);
   • Specifically included the post of Pharmacist among such identified posts;
   • Prescribed detailed physical requirements for the post, such as: sitting, seeing, reading and writing, communication, standing, walking, hearing, pushing & pulling, and manipulation of fingers.
2. Notification dated 26/27.09.2022
   Issued under Sections 33 and 34 of the RPwD Act, 2016, this notification:
   • Re-identifies posts for 4% reservation in favour of persons with benchmark disabilities, including the post of Pharmacist (at Serial No. 24);
   • Again specifies:
     • The physical requirements of the post, and
     • The categories of disabilities considered “suitable” for that post, sometimes with the aid of assistive devices or appliances.

The Court views these notifications as having a dual function:

• They enable reservation for persons with disabilities, by formally identifying posts under Sections 32/34-type schemes.
• They also limit the scope of which types and degrees of disabilities are considered compatible with the essential functions of the post.

In the Court’s reasoning, once such a notification exists and is not under challenge, it becomes the binding framework for assessing disabled candidates’ suitability. Any Medical Board or departmental committee must therefore evaluate candidates against those notified standards.

3. Deference to Expert Bodies: Medical Board and Departmental Committee

The Court repeatedly emphasises that the Medical Board and the departmental scrutiny/assessment committee are expert bodies.

The sequence of expert evaluation is instructive:

• Initial disability certificate records 50% permanent locomotor disability.
• Further examinations (including at PGIMER and by a neurologist at AIMSS/IGMC) lead to a detailed diagnosis:
  • Left hemiparesis (weakness of the left side of body);
  • Left homonymous hemianopia (loss of left visual fields in both eyes);
  • Left facial weakness;
  • History of right temporal craniectomy for tubercular brain abscess.
• Dr. Sudhir Sharma’s opinion states that the petitioner needs assistance in activities of daily living but can perform essential pharmacist duties with “some accommodation and assistance”.
• The departmental committee, however, after reviewing Dr. Sharma’s opinion, the disability certificate, and the 26.09.2022 Notification, concludes that the petitioner does not fall within the suitable disability categories and does not meet the physical requirements (notably standing and walking) for the post.

Justice Sharma ultimately accepts the departmental committee’s conclusion, despite the seemingly supportive statement by Dr. Sharma that the petitioner could work “with accommodation and assistance.” The Court does not delve deeply into the conflict between:

• The medical feasibility of the petitioner performing essential tasks with accommodation, and
• The administrative conclusion that, under the notification’s categorical standards, he is still unsuitable.

Instead, the Court frames the question as whether there is any illegality in the State’s decision, and answers in the negative, emphasising that:

• Pharmacists are required to undertake physically demanding tasks, including:
  • giving first aid and injections,
  • attending emergencies during off-hours,
  • assisting and managing medical and surgical stores, and
  • at times, travelling to patients’ houses.
• These functions require proper standing and walking, which the petitioner lacks to the degree required.

Consequently, the Court defers to the combined assessment of the Medical Board and the departmental committee as to the petitioner’s functional unfitness for the Pharmacist role.

4. Distinguishing Between General Entitlement and Post-Specific Eligibility

A recurring implicit theme in the judgment is the distinction between:

• A general entitlement to reservation or opportunity under the disability law; and
• An actual right to appointment to a specific post with defined functional requirements.

The Court accepts that:

• The post of Pharmacist is indeed an identified post for reservation under the disability quota;
• Persons with disabilities are entitled to be considered against those reserved posts; and
• Beneficial legislation must be interpreted in a pro-disability and humane manner.

Yet, it also holds that:

Not every disabled person—nor every person with a particular kind of disability—will necessarily be found suitable for every identified post. Identification for reservation is not equivalent to a guarantee of appointment to all candidates who have any disability plus the requisite qualifications.

Thus, disability-based reservation is post-specific and function-dependent.

D. Impact and Implications of the Judgment

1. For Disabled Aspirants in “Physically Demanding” Posts

The judgment sends a clear, if restrictive, message:

• Where posts involve significant physical activity—such as pharmacists in primary health centres and hospitals— the State is entitled to prescribe strict physical requirements (standing, walking, manual handling etc.).
• Even if a person has a benchmark disability and belongs to a reserved category, they may still lawfully be denied appointment if they fail to meet those notified functional standards.

This may particularly affect candidates with:

• Locomotor disabilities affecting gait and balance;
• Neurological sequelae affecting motor function or coordination;
• Combined sensory and motor impairments.

2. Litigation Strategy: The Need to Challenge Exclusionary Notifications

From a legal strategy standpoint, the judgment strongly suggests that candidates who feel unfairly barred by post-specific disability criteria must:

• Directly challenge the underlying notifications/rules (e.g., the 26.09.2022 Notification), arguing that:
  • the list of “suitable” disabilities is too narrow, or
  • the physical requirements are unreasonable or incompatible with the doctrine of reasonable accommodation under the RPwD Act, 2016.
• Rely on constitutional grounds (Articles 14, 16, 21) and the RPwD Act to contest such criteria as discriminatory.

By not challenging the notification, the petitioner in this case conceded, in effect, the validity of:

• the classification of suitable disabilities for the Pharmacist post; and
• the insistence on specific physical abilities (standing, walking, etc.).

The High Court, therefore, refused to bypass or dilute the unchallenged notification in an individual case.

3. Interaction with the Principle of Reasonable Accommodation

One of the more subtle tensions in the judgment lies in its muted engagement with the concept of reasonable accommodation.

The neurologist’s opinion that the petitioner could perform “essential duties of a pharmacist with some accommodation and assistance” echoes the language of reasonable accommodation—modifying or adjusting the workplace to allow a person with disability to perform the core functions of a job.

However, the Court does not explicitly evaluate:

• Whether the State was obliged under Section 2(y) and other provisions of the RPwD Act, 2016 to consider reasonable accommodation before declaring him unfit;
• Whether tasks such as travel to patients' houses and some physically demanding duties are essential functions of every Pharmacist post, or whether reallocation of certain duties could have been explored;
• Whether the presence of unfilled posts under other disability sub-categories (e.g., partially deaf) had any bearing on the possibility of accommodating the petitioner.

Instead, the Court largely accepts the departmental committee’s conclusion under the 26.09.2022 Notification, without probing whether its application fully satisfied the statutory requirement of reasonable accommodation. Future litigants may, therefore, attempt to use this tension to argue for a more robust, explicit application of reasonable accommodation in similar factual matrices.

4. Judicial Deference vs. Judicial Protection in Disability Rights

In comparative perspective with recent Supreme Court decisions, especially the Recruitment of Visually Impaired case, the present judgment shows a degree of judicial deference to the executive in:

• Defining which disabilities are “suitable” for which posts; and
• Accepting expert committee assessments of functional capacity at face value.

This stands in some tension with the Supreme Court’s trend of more searching review of exclusionary rules in disability employment, where the Court has been willing to test:

• Whether exclusions are narrowly tailored;
• Whether assistive technologies and accommodations can mitigate the impact of disability;
• Whether blanket “unsuitability” labels are evidence-based or based on stereotypes.

In Sajil Kumar, however, the High Court focuses more on:

• the non-challenge to the notification;
• and the expert status of the Medical Board and departmental committee.

Thus, while not hostile to disability rights, the judgment adopts a more deferential, rule-bound stance, which may be criticised by some as underplaying the transformative potential of the RPwD Act, 2016.

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IV. Complex Concepts and Legal Terms Explained

1. Writ of Certiorari

A writ of certiorari is a constitutional remedy used by High Courts (and the Supreme Court) to:

• Quash orders or decisions of subordinate courts, tribunals, or public authorities that are illegal, arbitrary, ultra vires, or passed without jurisdiction.

In this case, the petitioner sought certiorari to quash the selection and appointment of respondent no. 4 to the Pharmacist post on the ground that it was unlawful to ignore the petitioner’s superior claim under the reservation.

2. Writ of Mandamus

A writ of mandamus is a command issued by a constitutional court directing a public authority to:

• Perform a public or statutory duty which it has failed or refused to perform.

Here, the petitioner sought mandamus directing the State to:

Set aside the appointment of respondent no. 4 and appoint him instead as Pharmacist (Allopathy) on a contract basis under the SC (PWD) category.

3. Identification of Posts for Reservation: PWD Act, 1995 and RPwD Act, 2016

Under both the earlier Persons with Disabilities Act, 1995 and the present RPwD Act, 2016, the Government is obligated to:

• Identify posts in various establishments which can be reserved for persons with disabilities;
• Reserve a certain percentage (previously 3%, now generally 4% under the RPwD Act) of vacancies in such posts for persons with benchmark disabilities.

“Identification” means the Government carefully examines each post to determine:

• What essential duties it involves; and
• Which types of disabilities (e.g., blindness, hearing impairment, locomotor disability, intellectual disability) can reasonably be accommodated in performing those duties, possibly with aids/appliances.

The Notifications of 2012 and 26/27.09.2022 in this case are precisely such identification notifications. They are legally significant because they:

• Enable reservation, but also
• Constrain which disability categories can compete for each identified post.

4. Locomotor Disability, Hemiparesis, and Hemianopia

• Locomotor Disability: A disability of the bones, joints or muscles leading to substantial restriction of movement of limbs or any form of cerebral palsy.
• Hemiparesis: Weakness on one side of the body (here, the petitioner had left hemiparesis), often resulting from brain injury or stroke.
• Homonymous Hemianopia: Loss of half of the field of vision in both eyes on the same side (here, left-sided), commonly resulting from damage to visual pathways in the brain.

In lay terms, the petitioner had:

• Weakness and reduced control over his left arm and leg;
• Visual field loss on the left side in both eyes;
• A history of serious brain surgery (right temporal craniectomy) for tubercular abscess.

These conditions materially affect physical mobility and spatial awareness, which was central to the State’s assessment that he could not adequately perform physically demanding pharmacist duties requiring robust standing, walking and manual handling.

5. Reasonable Accommodation

Under the RPwD Act, 2016, “reasonable accommodation” means:

Necessary and appropriate modification and adjustments, without imposing a disproportionate or undue burden, to ensure persons with disabilities the enjoyment or exercise of rights equally with others.

In the employment context, this might include:

• Adjusting workstations or tools;
• Re-allocating non-essential duties to co-workers;
• Providing assistive technologies or aids;
• Flexible scheduling or support staff.

The neurologist’s note that the petitioner could perform essential duties “with some accommodation and assistance” implicitly invokes this concept. However, the departmental committee and Court did not explicitly apply or test the extent to which reasonable accommodation could, or should, have been deployed in this case.

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V. Conclusion: Key Takeaways and the Judgment’s Place in Disability Jurisprudence

1. Key Takeaways

1. Reservation is Not an Absolute Right to Appointment
   The case reinforces that reservation under the disability quota does not automatically ensure appointment. A candidate must not only:
   • possess the necessary educational qualifications, and
   • hold a valid disability certificate,
   but also:
   • meet the post-specific physical requirements and fall within the categories of disability deemed suitable under Government notifications.
2. Disability Certificates Are Subject to Employer’s Functional Assessment
   Where a disability certificate explicitly states that appointment is “subject to the employer’s conditions”, the employer—and by extension expert medical/departmental committees—retain the authority to judge whether the candidate can perform the essential functions of the job.
3. Importance of Challenging Exclusionary Rules Directly
   If the notified physical requirements or “suitable disability categories” for a post are themselves discriminatory, contrary to the RPwD Act, or inadequately accommodating, they should be challenged directly (as in the Recruitment of Visually Impaired case). An individual writ petition focusing only on non-selection will rarely succeed in indirectly overturning unchallenged notifications.
4. Judicial Deference to Expert Bodies in Service Matters
   The High Court displays considerable deference to the Medical Board and departmental committee, treating their assessments as dispositive of the petitioner’s functional unsuitability. This reflects the broader trend that courts will seldom substitute their own view for that of specialised medical or technical bodies in service jurisprudence, absent clear illegality, mala fides, or arbitrariness.
5. Limited Engagement with Reasonable Accommodation
   Although the neurologist’s opinion suggested the petitioner could perform pharmacist duties with accommodation, the judgment does not fully explore whether the State complied with its statutory obligation to consider reasonable accommodation under the RPwD Act, 2016. This leaves a space for future litigation to press more forcefully on this doctrinal front.

2. Broader Significance in Disability Law

Placed within the evolving landscape of disability rights jurisprudence in India, Sajil Kumar v. State of H.P. can be seen as a conservative and deferential application of the disability framework, as opposed to a transformative or expansionist one.

On the one hand, the judgment:

• Affirms the legitimacy of post-specific physical requirements and suitability criteria for disability reservation;
• Upholds the binding force of identification notifications issued under the disability statutes;
• Recognises the expertise of medical boards and departmental committees.

On the other hand, it:

• Does not aggressively scrutinise whether those criteria or their application are consistent with the spirit of reasonable accommodation and equality;
• Distinguishes, rather than builds upon, the Supreme Court’s recent pro-inclusion stance in the Recruitment of Visually Impaired decision.

For practitioners and scholars, the case is instructive in at least three respects:

1. It underscores the centrality of Government notifications in structuring disability reservation in employment;
2. It provides a practical roadmap of how disputes over functional suitability for posts will be evaluated by courts— heavily anchored in expert reports and unchallenged rules;
3. It highlights an emerging fault line in disability jurisprudence: the tension between a guarded, rule-bound approach at some High Courts and the more affirmative, accommodation-driven approach that the Supreme Court has increasingly adopted.

Ultimately, Sajil Kumar operates as a cautionary precedent for disabled aspirants in posts with significant physical demands: eligibility under a reserved category and possession of a disability certificate will not, by themselves, surmount structured, rule-based determinations of functional (un)fitness unless the underlying criteria are themselves successfully challenged.