In a landmark ruling that emphasizes the importance of supporting armed forces personnel, the Kerala High Court upheld a decision by the Armed Forces Tribunal to grant a disability pension to a retired Subedar Major (Honorary Captain) Mohanraj T.K. The High Court’s order, delivered by a Division Bench comprising Justices K. Natarajan and Johnson John, asserted that classifying Type-II Diabetes Mellitus and Primary Hypertension solely as “lifestyle disorders” is insufficient grounds for denying disability pension benefits.
The case originated when Mohanraj, a veteran from the Madras Engineer Group, sought pension after being invalidated from service on medical grounds. The Release Medical Board assessed his conditions—Type-II Diabetes Mellitus (20%) and Primary Hypertension (30%)—but concluded that they were not service-related, citing “lifestyle modification.” Consequently, his initial pension claim was denied. Following this setback, he appealed to the Armed Forces Tribunal, which ruled in his favor on 12 January 2024.
The Tribunal directed the authorities to acquire a composite degree of disability from a competent Medical Board within three months and ordered the issuance of a pension payment order along with arrears. This decision was contested by the Union of India in the High Court, which claimed interference in the Medical Board’s opinion.
In its judgment, the High Court presented several critical legal and procedural points rooted in service jurisprudence and regulatory guidelines. One pivotal aspect was Regulation 423 of the Regulations for Medical Services for the Armed Forces, which stipulates that a condition causing discharge is presumed to have arisen during service if there was no record of it at the time of enrollment. The Court emphasized that since no medical issues had been documented when Mohanraj joined the service, he was entitled to this presumption. The Board’s reliance on the lifestyle label did not meet the required standard to refute this presumption.
The High Court also highlighted that the burden of proof lies with the employer—the Union of India—following precedents set by earlier Supreme Court rulings. These decisions assert that armed forces members are presumed healthy upon entering service, with any deterioration presumed service-related unless proven otherwise.
Furthermore, the Court criticized the classification of diabetes and hypertension as mere lifestyle diseases, stating that such designations do not provide adequate justification for denying pension benefits. It pointed out that the rigors of military life contribute to numerous health challenges that should not be simplistically categorized as personal lifestyle choices.
Moreover, the High Court reinforced the limited scope of its jurisdiction under Article 226 of the Constitution, which aims to prevent manifest injustices rather than reevaluate every detail of Tribunal findings. It held that the Government’s duty extends beyond mere compliance with policies to encompass a broader commitment to veterans’ welfare.
The conclusion of the case saw the dismissal of the Union’s petition, mandating that authorities recognize Mohanraj’s disability and provide the necessary pension as ordered by the Tribunal.
This ruling is expected to significantly influence future cases related to disability pensions for service members, emphasizing that terms like “lifestyle disorder” cannot undermine statutory rights and proletariat entitlements. The High Court’s strong stance serves as a reminder of the institutional responsibilities toward personnel who dedicate themselves to national service and suggests that the benefit of the doubt in medical assessments should favor the soldier.
