Non-updated nomenclature of hospital can’t be ground to deny medical reimbursement, High Court

The Dharwad bench of the Karnataka high court has said 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. “Denial of reimbursement merely on account of non-updated nomenclature, when the entity remains the same, is arbitrary and legally unsustainable,” Justice Suraj Govindaraj said while directing the Higher Education Department to reconsider within six weeks the application filed by the petitioner.

The petition was filed by Shivanandappa Doddagoudar, associate professor in a government first grade college at Ranebennur, Haveri district. He challenged the endorsements issued in July and August 2024, by the Higher Education Department and Suvarna Arogya Suraksha Trust, rejecting his medical reimbursement claim of Rs 13,95,464. The petitioner contended that rejection was solely on the ground that the hospital does not find a place in the Government recognised list of private hospitals eligible for medical reimbursement.

According to the petitioner, 'Kasturba Medical College Hospital, Manipal', where he took treatment, was in the approved list. However, pursuant to a formal request dated March 23, 2021, the hospital sought a change of name to 'Kasturba Hospital, Manipal', in conformity with the registration certificate issued by the Karnataka Private Medical Establishment Authority, Udupi. He said the application was rejected since the updated name had not been incorporated in the government list.

Justice Suraj Govindaraj noted that 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, and the said recognition involves inspection and assessment of the hospital’s infrastructure and services.

“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,” Justice Suraj Govindaraj said.

The court further said, “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.”