Medical Reimbursement Cannot Be Withheld Solely Due to Change in Hospital’s Name | Karnataka High Court
Sanchayita Lahkar
The High Court of Karnataka, at Dharwad, Single Bench of Justice Suraj Govindaraj held that government employees cannot be denied medical reimbursement solely because a recognised hospital underwent a change of name. Invoking Clause (ff) of Rule 3 of the Karnataka Government Servants (Medical Attendance) Rules, 1963, the Court quashed the rejection orders and directed authorities to reassess the petitioner’s claim concerning treatment at Kasturba Hospital, Manipal. Stating that the institution continued as the same entity despite its updated nomenclature, the Court directed that the reimbursement claim be reconsidered and decided within six weeks.
The petitioner, Dr. Shivanandappa Doddagoudar, an Associate Professor at Government First Grade College, Ranebennur, filed a writ petition before the High Court of Karnataka, Dharwad Bench, challenging the rejection of his medical reimbursement claim. The respondents included the State of Karnataka through the Department of Health and Family Welfare, the Executive Director of the Suvarna Arogya Suraksha Trust, the Director of Collegiate Education Department, and the Under Secretary to Government (Collegiate), Higher Education Department.
The petitioner sought three primary reliefs: quashing of the order dated 03.07.2024 passed by the Under Secretary to Government (respondent no. 4); quashing of two orders dated 31.08.2024 issued by the Executive Director of the Suvarna Arogya Suraksha Trust (respondent no. 2); and a mandamus directing reimbursement of Rs. 13,95,464 along with interest. He argued that rejection of his claim was arbitrary and unsustainable.
The petitioner’s grievance arose because his medical expenses were not reimbursed on the ground that the hospital where he received treatment, Kasturba Hospital, Manipal, was not reflected in the official list of private hospitals recognised for medical reimbursement. The respondents took the position that only hospitals appearing in the approved list, without variation in name, could be considered eligible under the Karnataka Government Servants (Medical Attendance) Rules, 1963.
In response, the petitioner pointed out that the hospital was earlier recognised under its previous name, “Kasturba Medical College Hospital, Manipal,” which appeared in the approved list. He produced evidence that the hospital had, by formal communication dated 23.03.2021, sought correction of its name to “Kasturba Hospital, Manipal” in line with the registration certificate issued by the Karnataka Private Medical Establishment Authority, Udupi. Despite this, the change was not reflected in the government’s list, leading to rejection of his claim.
The Court considered Clause (ff) of Rule 3 of the Karnataka Government Servants (Medical Attendance) Rules, 1963, which mandates recognition of certain hospitals for reimbursement based on inspection and approval. It observed that the purpose of the recognised list was to ensure treatment at approved institutions, and that reimbursement would not be permissible if treatment was availed from an unrecognised hospital. However, in this instance, the hospital was a recognised entity that had undergone only a change of name.
The Court found that refusal to reimburse on this ground was legally untenable. It quashed the impugned orders and directed respondent no. 2 to reconsider the petitioner’s application, taking the name change into account, and to complete the process within six weeks of receiving the order
The Court stated: “The short grievance of the petitioner is that his medical reimbursement claim has been rejected solely on the ground that the hospital from which he availed treatment does not find a place in the Government-recognised list of private hospitals eligible for medical reimbursement.”
The Court recorded: “The hospital in question ‘Kasturba Medical College Hospital, Manipal’ was indeed present in the approved list. However, pursuant to a formal request dated 23.03.2021, the hospital sought for change of name to ‘Kasturba Hospital, Manipal’, in conformity with the registration certificate issued by the Karnataka Private Medical Establishment Authority, Udupi.”
The Court noted the respondents’ contention: “The learned Additional Government Advocate contends that only the names of hospitals appearing as is in the approved list can be considered and that deviations, including name changes, cannot be accepted.”
The Court thereafter framed the issue: “The only question that arises for consideration is: 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?”
The Court observed: “The purpose of maintaining a recognised list of private hospitals 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.”
While acknowledging that reimbursement cannot be permitted for treatment in unrecognised hospitals, the Court clarified: “It is evident that if treatment is availed from an unrecognised hospital, reimbursement is not permissible. However, in the present case, Kasturba Medical College Hospital, Manipal was an approved institution.”
The Court then remarked on the failure to update the hospital’s name in the list: “Following its name change to Kasturba Hospital, Manipal, the hospital submitted a formal application on 23.03.2021 seeking correction in the recognised list. Despite this, the authorities have failed to update the name, resulting in rejection of reimbursement claims.”
The Court recorded: “The hospital remains the same legal entity, and the name change was duly recorded under the Karnataka Private Medical Establishment Act. 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 after following the due procedure. Their failure to do so cannot prejudice the petitioner.”
The Court stated: “I answer the point framed by holding 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.”
Justice Suraj Govindaraj stated: “Writ petition is allowed.” The Court further ordered: “A writ of certiorari is hereby issued, quashing the order passed by respondent No. 4, dated 03.07.2024 (Annexure–C), and also the orders passed by respondent No. 2, dated 31.08.2024 (Annexures–E and E1).”
“Respondent No. 2 is directed to reconsider the petitioner’s application for medical reimbursement, taking into account the change in the name of Kasturba Medical College Hospital, Manipal to Kasturba Hospital, Manipal, in accordance with applicable procedure.”
“The said reconsideration shall be completed within a period of six weeks from the date of receipt of a certified copy of this order.”
Advocates Representing the Parties
For the Petitioners: Sri. Harshawardhanagouda Patil, Advocate
For the Respondents: Sri. Sharad V. Magadum, Additional Government Advocate
Case Title: Dr. Shivanandappa Doddagoudar vs. The State of Karnataka & Others
Neutral Citation: 2025: KHC-D:11704
Case Number: WP No. 106571 of 2025
Bench: Justice Suraj Govindaraj
