RTE and RPwD Acts Held Inapplicable to Sainik Schools: Madras High Court Upholds Non‑Negotiable Medical Fitness Standards and Estoppel Against Post‑Participation Challenges

Case: M.R. Yajith Krishna v. Union of India & Anr.

Neutral Citation: 2025:MHC:2272

Court: Madras High Court

Coram: Justice G.K. Ilanthiraiyan

Date of Decision: 22 September 2025

Cause Title: W.P. No. 29225 of 2025; W.M.P. Nos. 32784 & 32788 of 2025

Introduction

This writ petition raised a recurring and sensitive question at the intersection of child rights, disability rights, and the specialized mission of Sainik Schools: can a minor candidate who has otherwise qualified on merit be denied admission to Class VI in a Sainik School solely on medical grounds relating to visual acuity under the Sainik Schools Society’s Standard Operating Procedure (SOP) for All India Sainik School Admission Counselling (AISSAC)? And, are the protections under the Right of Children to Free and Compulsory Education Act (RTE) and the Rights of Persons with Disabilities Act, 2016 (RPwD Act) available to challenge such standards?

The petitioner, a 12-year-old boy from the Scheduled Caste category, secured 227/300 in the All India Sainik School Entrance process for Sainik School, Amaravathi Nagar (Udumalpet), but was rejected after two medical boards found him unfit under the prescribed eye standards in the AISSAC SOP. He sought (i) a declaration that the SOP’s eye standards for Class VI admissions are null and void insofar as they disqualify him, (ii) quashing of the Principal’s rejection dated 14.07.2025, and (iii) a consequential direction for admission.

The central issues were: (1) the legal validity and enforceability of the SOP’s ocular fitness criteria at the Class VI level; (2) the applicability of the RTE Act and the RPwD Act to Sainik Schools administered by the Ministry of Defence; and (3) whether a candidate who has participated in the selection process under known rules can subsequently challenge those very rules upon being found medically unfit.

Summary of the Judgment

Nature and mission of Sainik Schools: The Court emphasized that Sainik Schools are fully residential institutions under the Sainik Schools Society and the Ministry of Defence, designed as feeder institutions to the National Defence Academy (NDA) and Indian Naval Academy (INA). Given this mission, medical fitness—particularly ocular standards—is “non-negotiable.”
Medical findings: The petitioner was examined first by Coimbatore Medical College Hospital and, on review, by the Military Hospital, Chennai. Both boards declared him unfit under the SOP’s eye standards. The Court recorded that his uncorrected visual acuity was worse than the SOP’s permissible threshold (Standard II: uncorrected VA up to 6/18 in both eyes, with Best Corrected Visual Acuity 6/6, and strict limits on refractive error and astigmatism).
Estoppel by participation: Having accepted the SOP and participated in the process—including seeking a review before a second medical board—the petitioner could not turn around and challenge the SOP after being declared unfit.
Non-applicability of RTE and RPwD Acts: The Court held that Section 12(c) of the RTE Act and Sections 3, 4, and 16 of the RPwD Act do not apply to Sainik Schools administered by the Sainik Schools Society/Ministry of Defence, given their specialized character and feeder role to the armed forces.
Outcome: Writ Petition dismissed; no costs; connected miscellaneous petitions closed.

Detailed Analysis

1) The SOP Ocular Standards and the Petitioner’s Medical Fitness

The SOP prescribes detailed ocular requirements for Class VI admissions. Key facets recorded by the Court include:

Standard-I: 6/6 & 6/6.
Standard-II: Uncorrected Visual Acuity (VA) 6/18 & 6/18, and Best Corrected Visual Acuity (BCVA) 6/6 & 6/6; Myopia less than –1.25 D spherical with maximum astigmatism less than ±0.50 D cylindrical; Hypermetropia less than +1.25 D spherical with maximum astigmatism less than ±0.50 D cylindrical.
Additional prohibitions/requirements: LASIK or equivalent not permitted; Colour vision CP II; no squint or morbid ocular conditions; no active trachoma or sequelae.

The petitioner’s uncorrected VA was found to be worse than 6/18 in both eyes (the record also notes 6/36 at one point), thereby exceeding the maximum permissible uncorrected deficit. On this basis, both medical boards concluded unfitness, leading to automatic rejection on the e‑counselling portal (the Principal is required by SOP to “click the reject button” upon an unfit report).

2) Precedents Cited

The judgment does not cite specific judicial precedents. Rather, it rests on:

the statutory and administrative framework governing Sainik Schools under the Ministry of Defence,
the binding nature of the SOP for AISSAC, and
general principles of judicial deference to specialized policy in defence‑related education, coupled with the doctrine that a candidate who participates under known conditions cannot later challenge them after an adverse outcome.

Although not cited in this order, the reasoning aligns with two settled streams of Indian jurisprudence:

Limited judicial review of policy choices in specialized or defence contexts: Courts typically refrain from substituting their views for those of expert bodies absent arbitrariness, mala fides, or patent illegality. This deference is especially pronounced where the policy is directly tethered to defence preparedness or training.
Estoppel against post‑participation challenges: The Supreme Court has consistently held that candidates who knowingly participate in a selection process cannot challenge its rules after being declared unsuccessful, unless the rules themselves are illegal or unconstitutional. The High Court’s articulation mirrors this principle.

The judgment’s categorical view on the non‑applicability of the RPwD and RTE frameworks to Sainik Schools is notable. While the order treats this as settled for such institutions, it may invite further appellate scrutiny to delineate the precise contours of when—and to what extent—disability‑inclusive obligations yield to the “inherent requirements” of defence‑oriented schooling.

3) Legal Reasoning Employed by the Court

The Court’s reasoning proceeds along three principal axes:

Teleology of Sainik Schools and rational nexus:
Sainik Schools exist primarily to prepare cadets for NDA/INA. That mission logically requires physical and ocular standards consistent with future defence service eligibility. The ocular criteria in the SOP thus bear a direct and rational nexus to the institution’s core objective. On this basis, the Court characterized medical fitness as “non‑negotiable.”
Binding nature of the SOP and procedural compliance:
The SOP explicitly makes admission conditional upon medical fitness. The petitioner underwent two independent medical examinations, including a review at a Military Hospital. The identical outcomes were treated as conclusive. The procedure afforded—examination and review—was found fair, and the Principal’s role under the e‑counselling protocol is ministerial once an “unfit” report is returned.
Estoppel by acceptance and participation:
By accepting the SOP terms, sitting the entrance test, and even invoking the review mechanism, the petitioner could not, after an adverse medical outcome, challenge the validity of the same SOP. This reaffirms the bar against approbation and reprobation in selection processes.

On the statutory challenge, the Court held that:

RTE Act (Section 12(c)): Not applicable to Sainik Schools under the MoD/Sainik Schools Society. The Court’s focus was on the institutional character and mission rather than the general obligations of schools under RTE.
RPwD Act (Sections 3, 4, 16; definition of “discrimination” in Section 2(h)): The Court concluded these provisions are inapplicable to this category of institution in view of their defence feeder role and mandated medical standards. In effect, the Court privileged the “inherent functional requirements” of military preparatory schooling over the broader inclusionary obligations invoked by the petitioner.

4) Impact and Forward‑Looking Implications

The judgment’s potential effects are significant:

Affirmation of strict medical screening at entry‑level: Even at Class VI, Sainik Schools may enforce stringent ocular standards—e.g., uncorrected VA limits, narrow thresholds for refractive error and astigmatism, prohibition of LASIK, and color vision requirements.
Narrowing the avenue for RPwD‑based challenges in defence‑linked schooling: The holding that the RPwD Act is “not applicable” to Sainik Schools, if read broadly, could curtail disability‑rights arguments in this specific educational stream. A narrower and more reconciliation‑oriented reading is also possible: that the RPwD Act does not override essential medical criteria integral to the purpose of such schools, rather than being wholly inapplicable. Future appellate guidance may refine this.
Entrenchment of participation estoppel: Candidates and guardians should anticipate that post‑participation challenges to known selection conditions will face a high bar, especially where specialized training or defence preparedness is involved.
Administrative implications: Sainik Schools may continue to rely on standardized medical boards and an e‑counselling system that implements rejection automatically upon an “unfit” finding. Institutions should ensure that standards are clearly publicized at the application stage and that review procedures remain robust and prompt.
Policy debate on proportionality and inclusive education: The case may stimulate discussion on whether some accommodations (e.g., permitting minor refractive error corrected with spectacles where BCVA is 6/6) could be compatible with the schools’ mission, and where the line must be drawn. The SOP already moderates by allowing uncorrected VA up to 6/18 and requiring BCVA 6/6, but prescribes tight refractive thresholds; whether those thresholds are empirically justified may be examined in broader policy reviews rather than courts.
Jurisdictional reach: As a single‑judge decision of the Madras High Court, the ruling is binding within its territorial jurisdiction and persuasive elsewhere. The issues are of nationwide relevance due to the pan‑India Sainik School network and may ultimately invite appellate or Supreme Court consideration for uniformity.

Complex Concepts Simplified

Uncorrected Visual Acuity (VA): How well a person sees without glasses or contact lenses. “6/18” means at 6 meters the person reads what a person with normal vision can read at 18 meters. A higher denominator indicates poorer uncorrected vision.
Best Corrected Visual Acuity (BCVA): Visual acuity after optimal correction with lenses. BCVA 6/6 is essentially “normal” corrected vision.
Myopia/Hypermetropia: Nearsightedness (minus diopters) and farsightedness (plus diopters), respectively. The SOP caps the degree of permissible refractive error even if BCVA is normal.
Astigmatism: Imperfection in the eye’s curvature causing blurred vision; measured in cylindrical diopters. The SOP caps it at ±0.50 D.
LASIK Not Permitted: Laser eye surgery is disallowed, consistent with many defence medical standards, particularly for minors and early cadet stages.
CP II (Colour Vision): Colour Perception Grade II, indicating good colour discrimination, often required for many defence roles.
Writ of Declaration (Art. 226): A constitutional remedy seeking a court’s declaration that a rule/policy/action is void or inapplicable.
Doctrine of Estoppel by Participation/Appropriation and Reprobation: A person cannot accept and act upon a set of rules to compete, and later challenge those rules after finding them disadvantageous post‑result.
Feeder Institution: A school whose curriculum and training are tailored to prepare students for entry into a specified higher institution or service (here, NDA/INA).

Observations on the Statutory Interface

The petitioner invoked RPwD Act Sections 3, 4, and 16 (equality, dignity, and inclusive education), and relied on Section 2(h) (definition of “discrimination” including denial of reasonable accommodation). The Court, however, treated the Sainik Schools’ defence‑centric function as determinative, stating that RPwD and RTE protections do not apply to “these kinds of schools.”

Two readings of this holding are possible:

Broad reading: RPwD and RTE frameworks are categorically inapplicable to Sainik Schools. This is what the text of the order states.
Narrow/functional reading: The RPwD and RTE frameworks do not override essential medical prerequisites intrinsic to defence‑oriented schooling. Under this lens, the statutes apply generally, but yield to “inherent requirements” where a tight nexus to the institution’s mission exists. This reading harmonizes statutory objectives with defence‑preparedness and may be more consistent with the constitutional principle of proportionality.

The Court did not undertake a proportionality analysis (suitability, necessity, and balancing) or a granular “reasonable accommodation” inquiry, because it disposed of the matter at the threshold—by deeming the statutes inapplicable and emphasizing the petitioner’s estoppel. Whether higher courts will require a more calibrated reconciliation between disability‑inclusion and defence‑training imperatives remains an open question.

Key Takeaways

Sainik Schools may enforce strict medical (including ocular) standards at the point of entry into Class VI, justified by their feeder role to defence academies.
The Madras High Court has held that RTE Section 12(c) and RPwD Act Sections 3, 4, and 16 are not applicable to such institutions, given their special character.
Where the SOP mandates medical fitness, an “unfit” declaration by designated medical boards is conclusive for admission purposes within the e‑counselling protocol.
Candidates who accept and participate under known rules, and even seek review within that framework, will face estoppel against challenging the rules post‑fact.
Future litigation may focus on the scope of this “non‑applicability” pronouncement and the extent to which reasonable accommodation can (or cannot) be reconciled with defence‑centric admission criteria.

Conclusion

In M.R. Yajith Krishna, the Madras High Court squarely prioritizes the defence‑oriented mission of Sainik Schools, upholding the non‑negotiability of medical fitness standards—even for entry into Class VI—and foreclosing post‑participation challenges to the governing SOP. The Court’s categorical view that the RTE and RPwD frameworks do not apply to Sainik Schools provides a clear, if stringent, precedent favoring institutional specialization over general inclusion mandates. At the same time, it leaves room for future appellate clarification on how disability‑inclusive principles are to be harmonized with the inherent requirements of defence preparatory education.

For now, the decision signals continuity: Sainik Schools can continue to enforce strict, defence‑aligned medical standards at the admission stage, and candidates must carefully self‑assess against those standards before opting into the selection process.