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Mohamed Ibrahim vs. The Chairman & Managing Director, TANGEDCO & Ors.

Civil Appeal · 2023 INSC 914Decided 16 Oct 2023
Civil Appeal No. 6785 of 2023
S. Ravindra Bhat · Aravind Kumar

Background

Mohamed Ibrahim, an electrical engineering graduate, cleared the recruitment process and was selected as Assistant Engineer (Electrical) by the Tamil Nadu Generation and Distribution Corporation (TANGEDCO) in 2015. Before he could join, a medical examination found he had mild colour vision deficiency, and the employer cancelled his selection and later terminated his service, even though the original recruitment notification had never specified any colour-vision requirement for the post. He challenged this at the Madras High Court, winning before a single judge but losing before the Division Bench, which upheld TANGEDCO's decision as a reasonable exercise of its discretion.

Decision Breakdown

The Supreme Court held that although Ibrahim's condition did not fit within the strict statutory categories of "disability" under the Rights of Persons with Disabilities Act, 2016, he was nonetheless entitled to "reasonable accommodation": a legal principle requiring employers to adjust roles for people with impairments without imposing undue burden. The Court found that TANGEDCO had multiple departments and posts (such as AE-General, AE-Material Management, AE-CAUP) where intensive colour-based work was not essential, and that the employer's offer to accommodate him only as a lower-grade Junior Assistant was inadequate and inconsistent with his qualifications. It set aside the High Court's Division Bench judgment and directed TANGEDCO to appoint him as Assistant Engineer (Electrical) from his original date of appointment, with full continuity of service and 50% back wages.

Lesson Learnt

An employer cannot reject a qualified candidate for a mild, non-disqualifying medical condition without first genuinely exploring reasonable accommodation within its own organisational structure, especially where the recruitment notification itself laid down no such medical criterion.

Official source (sci.gov.in)View Judgment (PDF)

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