Chhattisgarh HC rules no second chance for forest recruitment walk test, says rules must be strictly followed

News Citation : 2026 LN (HC) 269 | 2026:CGHC:18228

April 21, 2026 : The High Court of Chhattisgarh has refused to grant relief to a group of candidates who sought a second chance to clear the physical walk test for recruitment to forest services, holding that such a relaxation would violate the governing rules and undermine the integrity of the selection process.

In a detailed judgment delivered on April 21, 2026, Justice Parth Prateem Sahu dismissed a batch of writ petitions arising out of the 2020 recruitment conducted by the Chhattisgarh Public Service Commission for posts of Forest Ranger and Assistant Conservator of Forest.

The dispute stemmed from candidates who had cleared the written examination and interview but failed to complete the mandatory 26-kilometre walk test within four hours. After the test held in September 2023, several unsuccessful candidates sought another opportunity, citing adverse conditions such as heat, traffic, and inadequate arrangements. Acting on these representations, the state government initially permitted a second attempt in January 2024. However, this decision was later withdrawn in June 2024 after objections were raised and the matter was re-examined.

The petitioners argued that the walk test was only a qualifying exercise and not linked to merit ranking, since no marks were awarded for it. They contended that denying a second chance would unfairly exclude more meritorious candidates who had performed well in the written and interview stages. They also claimed that the government could not arbitrarily reverse its earlier decision granting another opportunity.

On the other hand, the state and competing candidates maintained that the physical test was a mandatory eligibility condition prescribed under the Chhattisgarh Forest (Gazetted) Services Recruitment Rules, 2015. They stressed that the recruitment advertisement clearly required candidates to complete the walk test within the stipulated time and explicitly stated that no second opportunity would be granted.

The court agreed with the respondents, holding that the walk test formed an essential part of the eligibility criteria. It observed that recruitment processes must strictly adhere to statutory rules and advertised conditions, which apply uniformly to all candidates. Allowing a second chance after candidates had already failed would amount to changing the rules of the game midway, which is impermissible in law.

The court further noted that neither the recruitment rules nor the advertisement provided for a second attempt. Even though the rules contained a relaxation clause, such power was vested in the Governor and had not been exercised in this case. The initial decision to grant another opportunity was found to be contrary to the rules, and the subsequent withdrawal was treated as a corrective step rather than an arbitrary reversal.

Rejecting the argument of discrimination, the court clarified that any isolated instance of relaxation in another case could not create a right to claim similar treatment. It reiterated that “negative equality” cannot be invoked to perpetuate an illegality.

The judgment emphasised that physical fitness standards, including the walk test, are directly linked to the functional requirements of forest service posts, which often involve traversing difficult terrain. Therefore, failure to meet these minimum standards disentitles a candidate from appointment.

With these findings, the High Court concluded that the petitioners were not entitled to a second chance and upheld the state government’s decision to cancel the earlier permission for a re-test.

Case Reference : WPS No. 7384 of 2024 (Khumendra Kumar Sahu vs State of Chhattisgarh & Others) — For Petitioner: Mr. Dhani Ram Patel, Advocate; For Petitioners in WPS Nos. 5373/2024 & 7394/2024: Ms. Sharmila Singhai, Sr. Advocate, assisted by Ms. Kanchan Kalwani and Mr. Anmol Gupta, Advocates; For Petitioners in WPS Nos. 6989/2024 & 1698/2025: Mr. Mateen Siddiqui with Ms. Apurva Pandey, Advocate; For Petitioners in WPS Nos. 7896/2025 & 3460/2025 and Respondent No. 6 in WPS No. 5373/2024: Mr. Amrito Das, Advocate; For Respondent State: Mr. Gary Mukhopadhya, Additional Advocate General; For Respondent PSC: Mr. Anand Mohan Tiwari and Dr. Sudeep Agrawal with Ms. Yogisha Tiwari, Advocates; For Intervenor: Mr. CJK Rao, Advocate.