Bombay High Court
SHIDHODHAN BHIMRAO SHINDEversusTHE UNION OF INDIA THROUGH ITS SECRETARY AND OTHERS
- Disposal
- DISPOSED OFF
Holding
The respondents must declare the petitioner’s recruitment result within four weeks, as the biometric mismatch does not justify further delay.
Summary
The petitioner, a qualified candidate for various Central Armed Police Forces posts, cleared all stages of the recruitment process but his result was withheld due to a biometric mismatch. Despite being declared fit after a medical re‑examination, the respondents refused to publish his result pending a forensic report that had not been produced. The petitioner filed a writ under Article 226 seeking a direction to declare his result and expedite the forensic report. The respondents argued that the result could not be released without the forensic verification. The Court noted that similar petitions before the Nagpur Bench had been decided in favor of the candidates and that the facts were identical. Relying on that precedent, the Court ordered the respondents to declare the petitioner’s result within four weeks, making the writ petition absolute.
Issues considered
- Can the recruitment authorities withhold a candidate's result solely on the basis of a biometric mismatch pending a forensic report?
- Does the petitioner have a right under Article 226 to obtain a declaration of his result within a reasonable time?
- Is the precedent set by the Nagpur Bench in Writ Petitions Nos.975, 976, and 977 of 2025 applicable to the present case?
Subjects
- recruitment
- biometric mismatch
- forensic report
- Article 226
- writ petition
- result declaration
- CAPFs
Judgment
2026:BHC-AUG:18560-DB
10-Writ Petition No.2502 of 2025.odt
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
BENCH AT AURANGABAD
WRIT PETITION NO.2502 OF 2026
Shidhodhan Bhimrao Shinde,
Age – 21 Years, Occ. Student,
r/o. Pangargaon, Mudkhed,
Dist. Nanded ..Petitioner
Vs.
1. The Union of India
Ministry of Home affairs,
Through Its Secretary.
North Block, New Delhi-110001.
2. The Union of India,
Ministry of Personnel,
Public Grievances & Pensions,
Through Its Secretary,
North Block, New Delhi - 110 001.
3. Central Forensic Science Laboratory,
HW4P+HXP Krishna Complex,
38/4, Mundhwa, Kharadi Road,
Yashwant Nagar, Kharadi Road,
Pune 411 011.
4. Staff Selection Commission,
Through Its Chairman,
Block No. 12, CGO Complex,
Lodhi Road, New Delhi-110003
5. Central Reserve Police Force,
Through Directorate General,
Block No.-1, C.G.O. Complex,
Lodhi Road, New Delhi-110 003 ..Respondents
2 10-Writ Petition No.2502 of 2025
----
Mr.Vrishabh Patil, Advocate h/f. Mr.Satej Jadhav, Advocate for petitioner
Mr.Rahul Bagul, Senior Panel Advocate for respondent nos.1 to 5
----
CORAM : SMT.VIBHA KANKANWADI &
AJIT B. KADETHANKAR, JJ.
DATE : APRIL 23, 2026
JUDGMENT :-
1. Rule. Rule made returnable forthwith. Heard finally with the
consent of the learned counsel appearing for both the sides.
2. The petitioner has approached this Court under Article 226
of Constitution of India seeking directions to the respondents to declare
his result for the recruitment to the post of Constable (GD) in Central
Armed Police Forces (CAPFs) and SSF, Rifleman (GD) in Assam Rifles and
Sepoy in Narcotics Control Bureau, pursuant to the advertisement issued
on 05.09.2024. It is the case of the petitioner that he possessed all the
requisite qualifications prescribed for the said post. The petitioner duly
applied and was permitted to appear for the written examination and
having cleared the same was also called for the physical efficiency test,
physical standard tests and document verifications. During the document
verification process, the biometric details of the petitioner were found to
3 10-Writ Petition No.2502 of 2025
be not matching with those recorded earlier in the recruitment database.
Despite such observation, the petitioner was permitted to appear for the
medical examination which was duly conducted by the respondents.
Even, upon subsequent biometric tests, the mismatch persisted.
Consequently, the petitioner was initially declared unfit and was directed
to undergo medical re-examination.
3. The petitioner thereafter underwent medical re-examination and
was declared fit and eligible for selection. The verification of documents
and the medical examination process was thus completed.
Notwithstanding his successful completion of all stages of the recruitment
process, the respondents withheld the result of the petitioner solely on
the ground of biometric mismatch, even though the final result for other
candidates was published on 15.01.2026.
4. According to the petitioner, the biometric mismatch is not a fault
attributable to him. The forensic report regarding the verification of
biometric data, forwarded by the respondents to the forensic department,
is still awaited for a considerable time without any progress. The
petitioner has therefore approached this court seeking directions to
4 10-Writ Petition No.2502 of 2025
expedite the process of obtaining the forensic report and or to direct the
respondents to publish his result so that he may participate in the
forthcoming training programme likely to commence within a few weeks.
5. The learned Advocate appearing for the respondents submitted
that the results in relation to biometric mismatch are still awaited, and
therefore, the result of the petitioner could not be declared till the receipt
of the forensic report. During the course of the hearing, the petitioner’s
Advocate also brought to the notice of this Court that the similarly
situated candidates have preferred Writ Petition No.975 of 2025 and
other companion matters before the Bombay High Court, Nagpur Bench
and those petitioners were also appearing in the same examination and
for the same position. Their results were also withheld only due to the
reason of biometric mismatch. He relied upon paragraph 8, 9 and 10
which reads thus:
“8. Having considered the rival submissions, it appears
that it is a matter of record that the petitioners’ candidature
was considered by the respondents, thereafter, the written
examination conducted is also successfully cleared by the
petitioners herein. Resultantly, the physical and document
verification was carried out. However, but for Biometric
mismatch which is conducted by the respondents
themselves, which is according to us is not attributable to
5 10-Writ Petition No.2502 of 2025
the petitioners herein, the petitioners have been otherwise
declared successful. Therefore, in our considered view, the
respondents are not justified in withholding the results since
the recruitment process has commenced in the month of
November 2023 and after lapse of substantial period, the
respondents are not justified in withholding the results of
the petitioners, to which petitioners are legitimately entitled
for, in the wake of petitioners’ successfully clearing the
written examination so also further act of medical re-
examination conducted by the respondents. Therefore, we
direct the respondents to declare the result of the petitioners
within a period of four weeks from today.
9. Needless to state that the candidature of the
petitioners deserves to be considered on their respective
merit and if the petitioners are otherwise qualified.
10. The writ petitions are allowed. Rule is made absolute in
the above terms with no order as to costs.”
6. Upon making a query with the respondent’s advocate, whether the
facts of the present petition and the facts before the Nagpur bench in the
above order are similar, he agreed and fairly submitted that all the
petitioners therein are similarly situated to the one which is before us in
the present petition.
7. In light of the order dated 30th June 2025, passed by the Division
Bench of the Bombay High Court, Nagpur bench in Writ Petitions No.975
6 10-Writ Petition No.2502 of 2025
of 2025, 976 of 2025 and 977 of 2025, this court finds that the facts and
issues involved in the present petition are identical and the ratio of the
said judgment squarely applies to the present case.
8. Accordingly, the present petition is allowed in terms of paragraphs
8, 9 and 10, extracted above. The respondents are directed to declare the
result of the petitioner within 4 weeks from the date of this order.
9. Rule made absolute in above terms, no orders as to costs.
[AJIT B. KADETHANKAR, J.] [ SMT. VIBHA KANKANWADI, J.]
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KBP
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