Legal Review and Analysis of Sujata Bora vs Coal India Limited & Ors 2026 INSC 53

Synopsis

The Supreme Court of India, in its judgment dated 13th January 2026, allowed the appeal filed by Sujata Bora against Coal India Limited’s refusal to appoint her as a Management Trainee on grounds of disability. The Court reinforced the principles of reasonable accommodation, substantive equality, and intersectionality under the Rights of Persons with Disabilities Act, 2016, and the Constitution of India. It directed the creation of a supernumerary post for the appellant, emphasizing the state’s obligation to secure the right to work for persons with disabilities.

1. Basic Information of the Judgment

Case Title: Sujata Bora v. Coal India Limited & Others

Citation: 2026 INSC 53

Court: Supreme Court of India

Bench: Justice J.B. Pardiwala and Justice K.V. Viswanathan

Jurisdiction: Civil Appellate Jurisdiction

Civil Appeal No.: 120 of 2026

Nature of Bench: Division Bench (not a Constitutional Bench)

Date of Judgment: 13th January 2026

2. Legal Framework

The judgment extensively interprets and applies the following legal instruments:

• Statutory Law:
  Rights of Persons with Disabilities Act, 2016 (RPwD Act)
  Section 2(y): Definition of “reasonable accommodation”
  Section 2(ze): Definition of “universal design”
  Section 2(s): Definition of “person with disability”

• Constitutional Provisions:
  Article 14: Right to Equality
  Article 21: Right to Life and Personal Liberty
  Article 41: Directive Principle on right to work, education, and public assistance for disabled persons
  Article 39(a): Directive Principle on adequate means of livelihood
  Article 37: Directive Principles as fundamental in governance
  Article 142: Power of the Supreme Court to pass decrees or orders for doing complete justice

• Precedents Relied Upon:
  Omkar Ramchandra Gond v. Union of India (2024 INSC 775)
  Anmol v. Union of India (2025 SCC OnLine SC 387)
  Om Rathod v. Director General of Health Services (2024 SCC OnLine SC 3130)
  Ch. Joseph v. Telangana SRTC (2025 SCC OnLine SC 1592)
  Rajive Raturi v. Union of India (2024) 16 SCC 654
  Jane Kaushik v. Union of India (2025 SCC OnLine SC 2257)
  Minerva Mills Ltd. v. Union of India (1980) 3 SCC 625

• International Framework:
  UN Guiding Principles on Business and Human Rights
  ILO Global Business and Disability Network guidelines
  Convention on the Rights of Persons with Disabilities (CRPD)

3. Relevant Facts of the Case

• The appellant, Sujata Bora, applied under the Visually Handicapped (VH) category for the post of Management Trainee in Coal India Limited (CIL) in response to a 2019 advertisement.

• She was called for document verification and initial medical examination (IME) in July 2021.

• In September 2021, she was declared “unfit” by CIL on the ground of having both visual disability and residuary partial hemiparesis.

• The appellant challenged this before the Calcutta High Court (Single Judge), which quashed the IME result and directed her consideration in the 2023 recruitment cycle.

• The Division Bench of the High Court reversed the Single Judge’s order, citing expiry of the recruitment panel.

• The Supreme Court, in interim orders, directed AIIMS to constitute a Medical Board for disability assessment.

• The AIIMS report dated 1st January 2026 assessed her disability at 57%, exceeding the benchmark of 40%.

4. Issues Before the Court

• Whether the appellant was wrongfully denied employment under the RPwD Act, 2016.

• Whether the High Court’s Division Bench was justified in setting aside the Single Judge’s order merely because the recruitment panel had expired.

• Whether the concept of “reasonable accommodation” under the RPwD Act mandates affirmative action in public employment for persons with benchmark disabilities.

• Whether intersectionality of disability and gender requires a tailored approach in ensuring substantive equality.

• Whether corporate entities like CIL have a responsibility under CSR and ESG frameworks to promote disability inclusion.

5. Ratio Decidendi

The Supreme Court held:

• The appellant’s disability (57%) exceeded the benchmark disability of 40%, making her eligible for reservation under the RPwD Act.

• The Division Bench erred in denying relief on technical grounds of panel expiry; the appellant’s right to employment was infringed at the first instance.

• The principle of “reasonable accommodation” under Section 2(y) of the RPwD Act is a gateway right ensuring substantive equality. It requires necessary modifications without undue burden.

• The state’s obligation under Article 41 (right to work) read with Articles 14 and 21 mandates proactive measures for disabled persons.

• Intersectionality of disability and gender necessitates a nuanced approach to eliminate compounded discrimination.

• Corporate Social Responsibility (CSR) and Environmental, Social, and Governance (ESG) norms obligate public sector undertakings to integrate disability inclusion as a strategic imperative.

6. New Legal Framework Established

• Expansion of Reasonable Accommodation: The Court clarified that reasonable accommodation is not limited to physical aids but includes procedural and policy modifications to ensure full participation.

• Intersectionality as a Legal Tool: The judgment explicitly incorporates intersectionality (disability + gender) as a lens for interpreting equality under the Constitution and RPwD Act.

• Corporate Duty Under CSR/ESG: It linked disability rights with CSR and ESG obligations, making it a strategic business and legal requirement for public and private enterprises.

• Supernumerary Posts as Remedy: The Court directed creation of a supernumerary post, recognizing it as a form of reasonable accommodation to remedy past discrimination.

7. Examination and Analysis by the Supreme Court

a. Concept of Reasonable Accommodation

• The Court cited Omkar Ramchandra Gond and Rajive Raturi to underscore that reasonable accommodation is a facet of substantive equality and a fundamental right.

• It emphasized that the duty to provide accommodation is “ex nunc” (immediate and context-specific).

b. Constitutional Synthesis of Fundamental Rights and Directive Principles

• Referring to Minerva Mills, the Court reiterated that Part III (Fundamental Rights) and Part IV (Directive Principles) are complementary.

• Article 41 (right to work) was read into Articles 14 and 21 to elevate the right to livelihood for disabled persons.

c. Intersectionality of Disability and Gender

• Relying on Jane Kaushik, the Court acknowledged that women with disabilities face compounded discrimination, requiring targeted accommodations.

d. Corporate Social Responsibility and Disability Inclusion

• The Court referenced UN Guiding Principles and ILO reports to hold that disability inclusion is integral to CSR and ESG compliance.

e. Medical Assessment and Benchmark Disability

• The Court relied on AIIMS’s expert report to objectively determine disability percentage, underscoring the importance of scientific assessment in disability claims.

8. Critical Analysis and Final Outcome

Critical Analysis:

• The judgment is progressive in its interpretation of reasonable accommodation and intersectionality.

• It bridges legal principles with corporate governance, expanding the horizon of disability rights beyond state action.

• However, the reliance on Article 142 (complete justice) to create a supernumerary post may raise questions about judicial overreach in policy matters.

• The decision sets a strong precedent for future cases involving multiple disabilities and delayed justice due to procedural delays.

Final Outcome:

• The appeal was allowed.

• The order of the Division Bench of the Calcutta High Court was set aside.

• CIL was directed to create a supernumerary post for the appellant as Management Trainee.

• The appellant was to be posted at North Eastern Coalfields, Margherita, Assam, with suitable accommodations like a separate computer and keyboard as per universal design.

• The Court expressed gratitude to counsel and medical experts for their cooperation.

9.  (MCQs)

1. Which section of the RPwD Act defines “reasonable accommodation”?
a) Section 2(s)
b) Section 2(y)
c) Section 2(ze)
d) Section 2(r)

2. Which constitutional article was read with Articles 14 and 21 to uphold the right to work for persons with disabilities?
a) Article 39(a)
b) Article 41
c) Article 37
d) Article 38

3. What was the percentage of disability assessed by AIIMS in Sujata Bora’s case?
a) 30%
b) 40%
c) 57%
d) 70%

4. Which concept did the Court use to address compounded discrimination faced by women with disabilities?
a) Reasonable classification
b) Intersectionality
c) Proportionality
d) Legitimate expectation