Supreme Court: Disability Pension Granted Despite Schizophrenia Diagnosis Due to Lack of Reasoning in Medical Board Opinion (2025)

Introduction

Date of the Judgment: May 07, 2025
Judges: Nongmeikapam Kotiswar Singh, J., Abhay S. Oka, J.

Can a disability pension be denied solely based on a medical board’s opinion without detailed reasoning? The Supreme Court of India addressed this critical question in a recent case concerning an army veteran diagnosed with Schizophrenia. The court emphasized the necessity of providing comprehensive reasons in medical reports to ensure fair consideration of disability pension claims.

This judgment highlights the importance of reasoned decision-making in cases affecting the rights and benefits of servicemen. The bench, comprising Justice Nongmeikapam Kotiswar Singh and Justice Abhay S. Oka, delivered the judgment.

Case Background

Rajumon T.M. was enrolled in the Indian Army as a sepoy on November 17, 1988. After serving for more than nine years, he was discharged due to a diagnosis of Schizophrenia. The Invalidating Medical Board, which convened on March 30, 1998, at the Command Hospital, Western Command, Chandimandir, determined that the onset of the disease occurred in August 1993, during a period when the appellant was serving in a peace station. The board concluded that the disability was neither attributable to nor aggravated by military service, and it assessed the disability at 30 percent for two years.

Consequently, the appellant’s claim for a disability pension was rejected by the CCDA (Pension), Allahabad, via a letter dated January 4, 1999, which was communicated to the appellant by the AMC Records on January 15, 1999.

Timeline

Course of Proceedings

Initially, the rejection of the disability pension was challenged before the first appellate committee, which dismissed the appeal. Subsequently, the appellant made an unsuccessful attempt to seek redressal through a Member of Parliament. The Ministry of Defence informed the appellant on November 7, 2009, that the matter had been considered and his appeal against the rejection of the disability pension claim had been turned down by the competent authority. It was also noted that he had not preferred a second appeal after the dismissal of his first appeal.

Aggrieved by the rejection of his claim for disability pension, the appellant approached the Armed Forces Tribunal, Original Bench at Kochi, in OA No.100 of 2011, which was heard alongside other applicants seeking similar reliefs. The Armed Forces Tribunal also rejected the application.

Legal Framework

The Supreme Court examined Regulation 173 of the Pension Regulations for the Army, 1961, which outlines the primary conditions for granting disability pensions. This regulation stipulates that a disability pension may be granted to an individual who is invalided from service due to a disability that is attributable to or aggravated by military service and is assessed at 20 percent or above.

Regulation 173 states:

“173. Primary conditions for the grant of disability pension. — Unless otherwise specifically provided a disability pension may be granted to an individual who is invalided from service on account of a disability which is attributable to or aggravated by military service and is assessed at 20 per cent or above.”

Appendix II to the Regulations further clarifies that disablement or death shall be accepted as due to military service if it is certified that the disablement is due to a wound, injury, or disease attributable to military service, or if it existed before or arose during military service and has been aggravated thereby.

Regulation 423 of the Regulations for Medical Services for Armed Forces, 1983, provides further clarification on attributing disability to service. It emphasizes that it is essential to establish a causal connection between the disability and the service conditions. All evidence, both direct and circumstantial, must be considered, and the benefit of reasonable doubt should be given to the individual.

Regulation 423 states:

“423. Attributability to service .—(a) For the purpose of determining whether the cause of a disability or death is or is not attributable to service, it is immaterial whether the cause giving rise to the disability or death occurred in an area declared to be a field service/active service area or under normal peace conditions. It is, however, essential to establish whether the disability or death bore a casual connection with the service conditions. All evidence, both direct and circumstantial, will be taken into account and benefit of reasonable doubt, if any, will be given to the individual…

(c) The cause of a disability or death resulting from a disease will be regarded as attributable to service when it is established that the disease arose during service and the conditions and circumstances of duty in the armed forces determined and contributed to the onset of the disease. Cases, in which it is established that service conditions did not determine or contribute to the onset of the disease but influenced the subsequent course of the disease, will be regarded as aggravated by the service. A disease which has led to an individual’s discharge or death will ordinarily be deemed to have arisen in service if no note of it was made at the time of the individual’s acceptance for service in the armed forces. However, if medical opinion holds, for reasons to be stated that the disease could not have been detected on medical examination prior to acceptance for service, the disease will not be deemed to have arisen during service.”

Arguments

Appellant’s Arguments:

• ✓ The appellant argued that he was found medically fit at the time of enrollment and that the disease developed during his service, unrelated to family conditions.
• ✓ Since the disease developed during his service, he was entitled to a disability pension.

Respondents’ Arguments:

• ✓ The respondents contended that the appellant was posted at a peace station when the disease onset, which could not have contributed to or aggravated the illness.
• ✓ The Medical Board confirmed that the disease was constitutional and not connected with service.
• ✓ The respondents relied on several decisions of the Supreme Court, including:
  • ✓ Union of India & Ors. vs. Keshar Singh, (2007) 12 SCC 675
  • ✓ Union of India & Ors. vs. Surinder Singh Rathore, (2008) 5 SCC 747
  • ✓ Secretary, Ministry of Defence and Ors. vs. A.V.Damodaran (Dead) through LRs. and others, (2009) 9 SCC 140
  • ✓ Union of India & Ors. vs. Jujhar Singh, (2011) 7 SCC 735
  • ✓ Union of India and Anr. vs. Talwinder Singh, (2012) 5 SCC 480
  • ✓ No. 14666828M EX CFN Narsingh Yadav vs. Union of India & Ors. (2019) 9 SCC 667

Issues Framed by the Supreme Court

1. Whether the order of discharge of the appellant and denial of disability pension to him based on a medical opinion without providing full reasons to support the opinion can be said to be valid.

Treatment of the Issue by the Court

Authorities

The court considered the following authorities:

• ✓ Regulation 173 of the Pension Regulations for the Army, 1961
• ✓ Appendix II to the Pension Regulations for the Army, 1961
• ✓ Regulation 423 of the Regulations for Medical Services for Armed Forces, 1983
• ✓ Union of India & Ors. vs. Keshar Singh, (2007) 12 SCC 675 – Supreme Court of India
• ✓ Union of India & Ors. vs. Surinder Singh Rathore, (2008) 5 SCC 747 – Supreme Court of India
• ✓ Secretary, Ministry of Defence and Ors. vs. A.V.Damodaran (Dead) through LRs. and others, (2009) 9 SCC 140 – Supreme Court of India
• ✓ Union of India & Ors. vs. Jujhar Singh, (2011) 7 SCC 735 – Supreme Court of India
• ✓ Union of India and Anr. vs. Talwinder Singh, (2012) 5 SCC 480 – Supreme Court of India
• ✓ No. 14666828M EX CFN Narsingh Yadav vs. Union of India & Ors. (2019) 9 SCC 667 – Supreme Court of India
• ✓ Baby vs. Union of India, 2003 (3) KLT 362 (FB) – Kerala High Court
• ✓ Veer Pal Singh v. Ministry of Defence, (2013) 8 SCC 83
• ✓ Maniben Maganbhai Bhariya v. Distt. Development Officer, Dahod, (2022) 16 SCC 343

Judgment

How each authority was viewed by the Court?

• ✓ Regulation 423(d): The Court emphasized the requirement to give reasons by the Medical Board about their opinion as it is necessary as also required under Regulation 423(d) for the reason that the fate of the future career of the serviceman is going to be decided by the opinion of the Medical Board, which is to be treated as final as regards the cause of disability and the circumstances in which the disability originated.
• ✓ Veer Pal Singh v. Ministry of Defence, (2013) 8 SCC 83: The Court cited this case to highlight the debilitating effects of Schizophrenia, noting that provisions for disability pension are beneficial and should be construed liberally.
• ✓ Maniben Maganbhai Bhariya v. Distt. Development Officer, Dahod, (2022) 16 SCC 343: The Court referred to this case to emphasize that social security legislations should be interpreted liberally with a beneficial interpretation.

The Supreme Court held that the order of discharge of the appellant and the denial of disability pension based on a medical opinion without providing full reasons to support the opinion could not be considered valid. The court emphasized that the requirement to provide reasons by the Medical Board is crucial and necessary for granting or denying disability pension.

The Court stated:

“In our opinion , the requirement to give reasons by the Medical Board is crucial, critical , decisive and necessary for the purpose of granting or denying disability pension and it is not a mere formality, but a necessary material on the basis of which the pension sanctioning authority has to decide about the grant or refusal of disability pension.”

The court also noted that the absence of clinical details and medical history in Part II of Form AFSMF-16 further weakened the Medical Board’s opinion.

“Therefore, we are of the view that in absence of the said particulars which are required to be recorded or mentioned which would reveal the medical history of the appellant , the opinion given by the Medical Board in Part III of the Form AFMSF -16 that the disease is a constitutional personality disorder cannot be sustained being violative of the mandate contained in Regulation 423 (d) of the Regulation .”

The court acknowledged the debilitating effects of Schizophrenia and the need for a liberal approach in dealing with such cases.

“Under these circumstances , a much more liberal view ought to be adopted while dealing with the cases of discharge of servicemen from service on account of suffering from Schizophrenia as they may face several impediments and difficulties in proving the casual connection of the said disease with the military service.”

The Supreme Court allowed the appeal, directing the respondents to grant the appellant disability pension with immediate effect, along with all attending benefits as per rules, but without arrears except for the last three years.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the lack of reasoning in the Medical Board’s opinion. The court emphasized that the Medical Board’s failure to provide detailed reasons for concluding that the appellant’s Schizophrenia was a constitutional personality disorder undermined the validity of the discharge and denial of disability pension.

The court’s reasoning was heavily based on legal principles and regulations, with a significant emphasis on the requirement for reasoned medical opinions. The factual aspects of the case, such as the appellant’s medical condition and service history, played a secondary role in the decision-making process.

Logical Reasoning:

The logical reasoning of the court can be summarized as follows:

Medical Board’s Opinion Lacks Reasons ↓ Medical Opinion is Arbitrary and Unsustainable ↓ Discharge and Denial of Disability Pension are Invalid ↓ Appellant is Entitled to Disability Pension

Key Takeaways

• ✓ Medical boards must provide detailed reasons for their opinions when assessing disability claims.
• ✓ The absence of reasoned opinions can render decisions regarding discharge and denial of disability pension invalid.
• ✓ A liberal approach should be adopted when construing beneficial provisions for servicemen, especially in cases involving debilitating conditions like Schizophrenia.

Directions

The Supreme Court directed the respondents to grant the appellant disability pension with immediate effect, along with all attending benefits as per rules. However, the appellant was not entitled to any arrears of invalid pension, except for the last three years.

Conclusion

The Supreme Court’s judgment underscores the importance of reasoned decision-making in cases affecting the rights and benefits of servicemen. By granting disability pension to an army veteran diagnosed with Schizophrenia, the court emphasized the necessity of providing comprehensive reasons in medical reports to ensure fair consideration of disability pension claims. This decision reinforces the principle that medical opinions, especially those impacting a serviceman’s career and benefits, must be based on sound reasoning and supported by relevant medical history and clinical details.