Court rules denial of medical claims based on age limit for dependants violates Article 14, endorses legitimate expectation doctrine.
In a significant judgment, the Uttarakhand High Court has set aside the denial of medical reimbursement to Karishma Bhatt, a family pensioner, emphasizing the improper application of age restrictions meant for dependents to a pensioner receiving benefits in her independent right. The court's decision, delivered by Justice Pankaj Purohit, underscores the arbitrary nature of denying Bhatt's claim and affirms her entitlement under the State Government Health Scheme.
Karishma Bhatt, the petitioner, challenged the rejection of her medical reimbursement claims which were denied on the grounds that she exceeded the age limit of 25 years, a criterion applicable to dependents of government employees. Bhatt, a family pensioner following the demise of her mother, a government servant, argued that she was wrongly classified as a dependent.
The court found that Bhatt, having been issued a Golden Card under the health scheme and subjected to regular deductions from her pension, was rightfully entitled to the scheme's benefits. Justice Purohit highlighted that the government's interpretation of applying dependent-specific provisions to Bhatt was legally flawed and arbitrary, thus violating Article 14 of the Indian Constitution which guarantees equality before the law.
The court further referenced the doctrine of legitimate expectation, stating that once the State extended the scheme benefits and accepted contributions from Bhatt, it could not retract the benefits on unfounded grounds. The court also noted the respondents' inconsistency as they had reimbursed part of her medical expenses earlier, acknowledging her eligibility under the scheme.
This ruling mandates the State to fulfill its obligation by reimbursing Bhatt's medical expenses incurred due to an accident requiring treatment at AIIMS, New Delhi. The court's decision is seen as a reinforcement of rights for family pensioners against arbitrary administrative decisions.
Bottom Line:
Family pensioner under a State Government Health Scheme cannot be denied reimbursement of medical expenses on the ground that she was above 25 years of age, as the age limit applies only to dependents of government servants/pensioners and not to family pensioners receiving pension in their own independent right.
Statutory provision(s): Article 14 of the Constitution of India, Doctrine of Legitimate Expectation
Karishma Bhatt v. State Of Uttarakhand, (Uttarakhand) : Law Finder Doc id # 2875651
