The Punjab and Haryana High Court has ruled that a Haryana government employee who spent over Rs 3.53 lakh on his father's medical treatment cannot be denied reimbursement merely because the father's monthly income, as per the Parivar Pehchan Patra, exceeded the prescribed dependency ceiling. Justice Sandeep Moudgil emphasized that genuine medical reimbursement claims cannot be defeated by a rigid and technical interpretation of executive instructions.
Court's Observation on Welfare Measures
Justice Moudgil stated that reimbursement of medical expenses is a welfare measure, not a bounty distributed at the whim of the administration. It is intended to secure humane conditions of existence for government employees and their dependent family members. The Bench allowed a petition filed by a government employee whose claim for reimbursement of Rs 3,53,995 incurred on his father's treatment was rejected solely because the father's monthly income of Rs 6,600, as per the Parivar Pehchan Patra, exceeded the ceiling prescribed under Haryana Government instructions dated December 14, 2007.
Details of the Case
The petitioner approached the High Court seeking quashing of the rejection order dated November 7, 2024. Justice Moudgil noted that the respondents did not dispute the genuineness of the treatment, the medical bills amounting to Rs 3,53,995, the chronic ailment suffered by the father, or the actual expenditure incurred by the petitioner. The Bench also noted that a Chronic Disease Certificate issued by the Civil Surgeon was on record.
Holding the respondents' approach legally unsustainable, Justice Moudgil observed: "The right of a government employee to seek reimbursement of genuine medical expenses incurred for the treatment of a family member cannot be defeated by adopting a rigid and technical interpretation of executive instructions."
Court's Directive
Setting aside the rejection order, Justice Moudgil directed the State and other respondents to reconsider and release the admissible medical reimbursement claim in accordance with law, along with interest at 6 per cent per annum from the date it became due until its realization. The Bench set a deadline of three months after receiving the certified copy of the order.
The Court further cautioned against an inflexible application of administrative instructions, observing: "The Court must also guard against a mechanical application of executive instructions where such interpretation results in denial of legitimate reimbursement claims despite admitted treatment and expenditure."
Constitutional Obligation
Emphasizing the object of the reimbursement scheme, the Bench asserted: "Reimbursement of medical expenses is not a bounty distributed at the whim of the administration. It is a welfare measure intended to secure humane conditions of existence for government employees and their dependent family members." The Court also noted that the respondents had neither alleged any fraud nor disputed the treatment undertaken by the petitioner's father. Holding that such a ground alone could not justify denial of reimbursement, Justice Moudgil observed: "Such a ground, by itself, cannot outweigh the constitutional obligation of the State to ensure medical assistance to its employees and their families, particularly when substantial medical expenditure has admittedly been incurred on the treatment of a chronic ailment."
