A Haryana government employee who spent over Rs 3.53 lakh on his father’s treatment could not have been denied medical reimbursement merely because his father’s monthly income—as reflected in the Parivar Pehchan Patra—exceeded the prescribed dependency ceiling, the Punjab and Haryana High Court has ruled.
Justice Sandeep Moudgil made it clear that genuine medical reimbursement claims could not be defeated by a rigid and technical interpretation of executive instructions.
The Bench ruled that reimbursement of medical expenses was a welfare measure. It was “not a bounty distributed at the whim of the administration", but one intended to secure humane conditions of existence for government employees and their dependent family members.
Justice Moudgil made the observations while allowing a petition filed by a government employee whose claim for reimbursement of Rs 3,53,995 incurred on the treatment of his father was rejected solely on the ground that his father’s monthly income of Rs 6,600 –– as reflected in the Parivar Pehchan Patra –– exceeded the ceiling prescribed under the Haryana Government’s instructions dated December 14, 2007, for treating a family member as a dependent.
Setting aside the rejection order dated November 7, 2024, 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 till its realization. For the purpose, the Bench set a deadline three months after receiving the order’s certified copy.
The petitioner had approached the High Court seeking quashing of the rejection order. Justice Moudgil noted that the sole ground for rejecting the claim was that the income of the petitioner’s father, as reflected in the Parivar Pehchan Patra, exceeded the ceiling prescribed under the Government instructions for treating a family member as a dependent.
At the same time, 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 petitioner’s father, or the actual expenditure incurred by the petitioner.
The Bench also took note of the fact that a Chronic Disease Certificate issued by the Civil Surgeon had been placed 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."
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."
Emphasising 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." Allowing the petition, the Court quashed the impugned order.
