yes you guys are right but there is a clause in the below mentioned link
if you read carefully clause 5(iii) theres a sentence " by re examination or otherwise that he still possess all the eligibilities required for issue or renewal of such licences"
now i don't understand the meaning of the word" otherwise " in that sentence
does that otherwise mean " any other way or means to prove your proficiency"
which in this case is training on a SIM
http://www.wpc.dot.gov.in/DocFiles/copcircular1.jpg