Anil Kumar S.B. v. KPTCL (2025): disability suitability needs a functional assessment, not just a medical certificate

When a public employer decides whether a person with a disability is fit for a particular post, what is it actually measuring? On 13 May 2025, a Division Bench of the High Court of Karnataka — N.V. Anjaria, C.J., and K.V. Aravind, J. — gave a clear answer in Anil Kumar S.B. v. Karnataka Power Transmission Corporation Ltd. Suitability, the Court held, is not exhausted by a doctor's certificate. It must be assessed functionally, against the real demands of the job and the candidate's real ability to meet them. The decision is a clean Karnataka application of the Rights of Persons with Disabilities Act 2016 to the mechanics of recruitment, and a reminder that medical certification is a floor, not the whole test.

The facts in brief

The appellant, Anil Kumar S.B., is a person with locomotor disability assessed at 75% or more. He was already in the employment of the Karnataka Power Transmission Corporation Limited (KPTCL), serving as an Assistant under the reservation for persons with disabilities. He then applied for direct recruitment to the higher post of Assistant Accounts Officer, again under the PwD category.

He was notified to sit the examination and did so. But when the provisional selection list was published, he was left out of it. The respondents' position was that no eligible PwD candidate existed for that category — in effect, that the reserved vacancy could not be filled by him. Anil Kumar challenged that exclusion before a Single Judge of the High Court, who dismissed his writ petition. He carried the matter in appeal to a Division Bench by way of Writ Appeal No. 1673 of 2024.

The questions

Two questions framed the appeal. The first went to method: may the suitability or eligibility of a candidate with a physical disability for a particular post be assessed solely on the basis of a medical certificate, or must the assessment also account for a functional evaluation of the candidate's actual capacity to perform the role under the RPwD Act 2016?

The second went to the consequence of scarcity: where sufficient PwD candidates are not available in the respective category, may the eligibility criteria be relaxed so that a reserved post is not simply allowed to lapse? The two questions are linked. If suitability is read narrowly — as a clinical box-ticking exercise — reserved posts will go unfilled and the very candidates the reservation exists to protect will be screened out at the threshold. If suitability is read functionally, the inquiry shifts to whether the person can in fact do the work.

What the Court held

The Division Bench allowed the appeal. It set aside the Single Judge's order and declared the appellant eligible for appointment as Assistant Accounts Officer under the PwD reservation.

The reasoning turned on the nature of the suitability inquiry. The Court held that the suitability of a candidate suffering from a physical disability must not be assessed solely on the basis of a medical certificate; it must also be tested through a functional assessment of the candidate. Undue emphasis cannot be placed on medical or clinical considerations alone when what is being judged is a person's capacity and capability to discharge a role. The certificate establishes the existence and extent of disability — it does not, by itself, answer whether the person can perform the job.

The Bench then addressed the scarcity point directly:

On the facts, the Court found the appellant's capability already demonstrated. He was discharging the duties of an Assistant under the PwD quota and was eligible for promotion — concrete evidence that he could perform work of the relevant kind. In reaching its conclusion, the Bench drew support from a Supreme Court ruling concerning the recruitment of visually impaired persons into the judicial services, a line of authority that treats functional capacity, supported where necessary by accommodation, as the touchstone for inclusion in public employment rather than a mechanical reading of impairment.

Analysis

The significance of Anil Kumar lies in where it locates the burden of the suitability question. The orthodox, and easier, approach for an employer is to treat a medical certificate as dispositive: the certificate records a disability and its percentage, and the recruitment machinery then asks only whether that quantum is compatible with some pre-set notion of the post. That approach has the appeal of administrative convenience, but it inverts the purpose of disability reservation. A reservation that exists precisely because candidates have disabilities cannot coherently use the existence of disability as the reason to exclude them.

The functional-assessment standard corrects that inversion. By insisting that the inquiry turn on what the candidate can actually do — and, by implication, on what the role actually requires — the Court aligns the selection process with the substantive-equality logic of the RPwD Act 2016. The Act is built on the idea that disability is a function of the interaction between an impairment and the environment, not a fixed disqualification; the right question is whether, with reasonable accommodation where needed, the person can perform the essential functions of the post. A medical certificate cannot answer that question because it never asks it.

The scarcity holding is the practical hinge. Reserved vacancies are routinely defeated by the assertion that "no eligible candidate is available," which can become a self-fulfilling outcome when eligibility is defined so rigidly that almost no PwD candidate clears it. By holding that relaxation of eligibility criteria can be considered when sufficient PwD candidates are not available in the category, the Bench closes off the easy route to leaving a reserved post unfilled. The reservation is meant to be filled, and the selection criteria must be applied with that object in view.

It also matters that the appellant was already doing analogous work. His existing appointment as an Assistant, and his eligibility for promotion, were not incidental facts — they were the strongest possible refutation of the claim that he was unsuitable. An employer that has already found a candidate capable of one role under the quota is poorly placed to argue, on certificate-driven grounds alone, that he is categorically unfit for a related, higher one. The Court treated demonstrated performance as evidence of capacity, which is exactly what a functional inquiry should do.

Why it matters

For public employers in Karnataka and beyond, Anil Kumar S.B. v. KPTCL is a working rule: a candidate with a disability cannot be excluded from a reserved post on the basis of a medical certificate alone. The certificate is the starting point, not the verdict. Recruitment authorities must undertake a functional assessment of whether the candidate can perform the role, and they cannot allow reserved vacancies to lapse for want of "eligible" candidates where the eligibility bar can fairly be relaxed.

For candidates and those advising them, the decision supplies a concrete handle. Where a PwD applicant is screened out on clinical grounds, the question to press is whether any functional assessment was ever conducted — and whether evidence of the applicant's actual capacity, including performance in an analogous role, was considered at all. Mechanical, certificate-driven exclusion is now squarely vulnerable to challenge under the RPwD Act 2016.

Related on Valkya

• Prabhu Kumar v. State of Himachal Pradesh (RPwD floor)
• State of Karnataka v. Umadevi
• Tej Prakash Pathak v. Rajasthan High Court

Sources

• LiveLaw, "Karnataka High Court | PwD Candidate Eligibility — Functional Assessment And Medical Fitness" — https://www.livelaw.in/high-court/karnataka-high-court/karnataka-high-court-ruling-pwd-candidate-eligibility-functional-assessment-and-medical-fitness-291945
• Verdictum, "Anil Kumar S.B. v. The Karnataka Power Transmission Corporation Limited" — https://www.verdictum.in/court-updates/high-courts/karnataka-high-court/anil-kumar-s-b-v-the-karnataka-power-transmission-corporation-limited-1577292
• LiveLaw, "Karnataka High Court Weekly Roundup: May 12 — May 18, 2025" — https://www.livelaw.in/high-court/karnataka-high-court/karnataka-high-court-weekly-roundup-may-2025-292601