The Rajasthan High Court upheld a decision of the State government directing the reassessment of disability certificates of employees who were appointed under the Persons with Disabilities reservation category. The Court dismissed a batch of petitions that challenged the government’s administrative order requiring employees appointed under the PwD quota to undergo reassessment of their benchmark disabilities. The Court observed that the State has a responsibility to ensure that reservation policies are implemented properly and that the benefits intended for persons with disabilities are availed only by those who are genuinely eligible.
The case arose after the Government of Rajasthan issued an administrative order directing compulsory reassessment of benchmark disabilities of employees who had obtained government jobs under the PwD category in previous years. The reassessment directive was issued after irregularities were reportedly detected in the evaluation of disability claims made by certain individuals who had secured public employment under the reserved category. In light of these concerns, the State government decided that it was necessary to verify the authenticity and correctness of the disability certificates submitted by such employees to ensure that the reservation system was not being misused.
Several employees challenged this directive before the High Court. They argued that disability certificates issued through the legally prescribed procedure under the Rights of Persons with Disabilities Act, 2016 should be treated as final and binding. According to the petitioners, once a disability certificate had been issued by the competent authority in accordance with the statutory framework, the State government could not question its validity or order reassessment. They further contended that the government’s decision to subject them to reassessment was arbitrary and discriminatory.
The petitioners also argued that the reassessment order violated their fundamental rights guaranteed under Articles 14, 16 and 21 of the Constitution. These provisions protect equality before the law, equal opportunity in matters of public employment and the right to life and personal liberty. According to the petitioners, requiring employees who had already secured employment under the PwD category to undergo reassessment created uncertainty regarding their employment and subjected them to unnecessary scrutiny.
Another argument raised by the petitioners related to the doctrine of reasonable accommodation under the Rights of Persons with Disabilities Act. They submitted that persons with disabilities are entitled to specific protections and accommodations in employment, and that requiring them to undergo reassessment after appointment undermined these protections. They contended that the directive placed an additional burden on persons who had already been recognized as eligible under the statutory process and therefore amounted to discrimination.
The High Court examined the submissions made by the petitioners as well as the justification provided by the State government for issuing the reassessment order. After considering the arguments, the Court rejected the contentions raised by the petitioners and upheld the validity of the government’s directive. The Court observed that the State possesses the authority to verify claims made by individuals seeking benefits under reservation policies, including those relating to disability.
The Court noted that the objective of such verification is to ensure that the benefits of reservation intended for persons with disabilities are actually received by those who legitimately qualify for them. If individuals who do not meet the eligibility criteria obtain these benefits through false or incorrect claims, the purpose of the reservation policy would be defeated. The Court therefore emphasized that the State must ensure that reservation policies are implemented fairly and transparently so that opportunities meant for eligible candidates are not wrongly taken away.
While examining the provisions of the Rights of Persons with Disabilities Act, the Court observed that the statute does not state that a disability certificate, once issued, becomes permanently binding for all purposes. The absence of such a provision indicates that the State is not prohibited from verifying the authenticity of disability claims if circumstances warrant such verification. The Court pointed out that the law itself recognizes the possibility that disability certificates may be misused.
The Court referred to the provisions of the Act that prescribe punishment for individuals who obtain benefits by using false or fraudulent disability certificates. According to the Court, the existence of such provisions demonstrates that the legislature was aware of the possibility of misuse and intended that safeguards should exist to prevent fraudulent claims. In this context, the reassessment of disability certificates was considered a legitimate administrative measure.
The Court also observed that public employment involves public posts funded by public resources, and therefore the State must exercise vigilance to ensure that the system is not abused. If fraudulent or incorrect claims are allowed to go unchecked, the benefits intended for persons with disabilities may be diverted to individuals who are not genuinely entitled to them. Such misuse would undermine the objectives of the reservation policy and deprive deserving candidates of opportunities that the law aims to provide.
While acknowledging the need to adopt a humane and inclusive approach toward persons with disabilities, the Court stated that inclusivity can only be achieved when policies are implemented in their true spirit. Preventing fraudulent claims was therefore seen as necessary to preserve the integrity of the reservation system. The Court explained that the rights of persons with disabilities must be protected while also ensuring that the legal framework designed to support them is not misused.
The Court then addressed the petitioners’ argument that the reassessment order violated constitutional guarantees of equality and equal opportunity in public employment. It held that the government’s action did not infringe these rights. Instead, the Court stated that the directive was consistent with the principles of transparency and fairness that guide public administration. Ensuring that only eligible individuals benefit from reservation policies was considered an essential part of maintaining equality in public employment.
Another issue considered by the Court was whether the reassessment directive was arbitrary because it applied to a large number of employees rather than targeting specific individuals suspected of wrongdoing. The Court observed that when irregularities are suspected in a large number of appointments, it may not be possible for the State to immediately identify which particular cases may involve fraudulent claims. In such circumstances, a general reassessment order applicable to all relevant employees can be justified as an administrative measure designed to verify eligibility.
The Court concluded that applying the reassessment requirement broadly to employees appointed under the PwD category during a particular period did not amount to arbitrary or discriminatory action. Instead, it was seen as a practical step taken by the State to ensure that the reservation system was functioning properly and that only eligible individuals were benefiting from it.
The Court also considered the petitioners’ claim that the reassessment order violated the principle of reasonable accommodation. It clarified that for such a claim to succeed, it must be shown that the government’s action was not taken in good faith or that it imposed an undue burden on the affected individuals. In the present case, the Court found no indication that the reassessment directive had been issued in bad faith or that it caused disproportionate hardship to the employees concerned.
The Court further addressed concerns that repeated reassessment could be used to harass employees in the future. It observed that if governments were to repeatedly require reassessment whenever there was a change in administration, such actions could potentially be challenged as contrary to legal principles. However, the Court noted that the reassessment order in this case was intended as a one-time measure aimed at verifying the authenticity of disability claims in light of reported irregularities.
In view of these findings, the Court held that the government’s decision to order reassessment did not violate any statutory provision or constitutional right. The directive was considered a legitimate step taken by the State to verify claims and ensure that the benefits of the disability reservation policy are granted only to those who genuinely qualify.
The Court ultimately upheld the government’s administrative order and dismissed the petitions challenging it. The judgment reaffirmed that the State has both the authority and the responsibility to examine the authenticity of claims made under reservation policies. At the same time, it emphasized the need to protect the integrity of legal frameworks designed to support persons with disabilities by preventing misuse and ensuring that benefits reach the individuals for whom they are intended.

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