Karnataka High Court: In a writ petition filed by petitioner challenging the rejection of his medical reimbursement claim by the State authorities due to change of the hospital name, a Single-Judge Bench of Suraj Govindaraj, J., set aside the rejection of reimbursement order holding that the denial of reimbursement merely on account of non-updated nomenclature, when the entity remains the same was arbitrary and legally unsustainable. The Court further observed that the authorities’ failure to update their records cannot prejudice the petitioner.
Background
The petitioner filed a writ petition challenging the rejection of his medical reimbursement claim by the State authorities on the sole ground that the hospital from which he availed treatment was not on the Government-recognised list of private hospitals eligible for medical reimbursement.
The petitioner submitted that the hospital was on the approved list but had subsequently changed its name to ‘Kasturba Hospital, Manipal’ in conformity with its registration certificate. The hospital had formally requested the authorities to update the name in the recognised list, but they failed to do so. Whereas the respondents argued that only hospitals with the exact names appearing on the approved list could be considered.
Issue
Whether medical reimbursement can be denied solely due to a change in the name of the hospital, even though it remains the same entity that was previously recognised?
Analysis and Decision
The Court noted that the purpose of maintaining a recognised list under Clause (ff) of Rule 3 of the Karnataka Government Servants (Medical Attendance) Rules, 1963, is to ensure that services are availed from vetted and approved institutions. The recognition involves inspection and assessment of the hospital’s infrastructure and services.
The Court acknowledged that reimbursement is not permissible if treatment is taken from an unrecognised hospital. The Court noted that in the present case, the hospital in question was an approved institution. Following its name change, it had submitted a formal application to seek a correction in the recognised list, but the authorities failed to update the name.
The Court observed that,
“Denial of reimbursement merely on account of non-updated nomenclature, when the entity remains the same, is arbitrary and legally unsustainable.”
The respondent authorities were obligated to verify the request and update the recognised list, and their failure to do so could not prejudice the petitioner.
The Court held that medical reimbursement cannot be denied solely due to a change in the name of the hospital, even though it remains the same entity that was previously recognised. The Court quashed the rejection order and directed the petitioner’s application to be reconsidered for medical reimbursement within six weeks, taking into account the name change of the hospital.
[Shivanandappa Doddagoudar v. State of Karnataka, 2025 SCC OnLine Kar 18939, decided on 10-09-2025]
Advocates who appeared in this case :
For the Petitioner: Harshawardhanagouda Patil Advocate
For the Respondents: Sharad V. Magadum, AGA
