Karnataka High Court, in a significant ruling, clarified that medical reimbursement to government servants cannot be denied merely because the hospital where treatment was taken changed its name. The judgment, delivered by Justice Suraj Govindaraj on 10 September 2025 in Dr. Shivanandappa Doddagoudar v. State of Karnataka & Ors., Writ Petition No. 106571 of 2025, sets an important precedent for employees facing arbitrary rejection of medical claims due to technicalities in administrative records.
Factual Background
- Petitioner: Dr. Shivanandappa Doddagoudar, Associate Professor at Government First Grade College, Ranebennur.
- Claim: Reimbursement of ₹13,95,464 for medical treatment.
- Ground of Rejection: Authorities refused reimbursement stating that the hospital from which treatment was availed—Kasturba Hospital, Manipal—did not appear in the Government’s recognised list of private hospitals.
However, the petitioner pointed out that the hospital was earlier listed as Kasturba Medical College Hospital, Manipal. The institution had officially changed its name in 2021 with the Karnataka Private Medical Establishment Authority’s approval and communicated the same to the authorities. Despite this, the government list was not updated, leading to rejection of reimbursement.
Issue
The core issue before the Court was:
Whether medical reimbursement can be denied solely due to a change in the hospital’s name, even though it remains the same entity that was previously recognised?
Arguments
Petitioner’s Submissions
- The hospital was already a recognised institution.
- Only the name changed—the infrastructure, services, and legal entity remained the same.
- Authorities failed to update the list despite receiving a formal request from the hospital in March 2021.
- Denying reimbursement caused undue hardship and was arbitrary.
Government’s Stand
- Only hospitals listed exactly as named in the approved list could be considered for reimbursement.
- Any deviation, including name change, disqualified a claim.
Court’s Observations
Justice Suraj Govindaraj made the following key observations:
Purpose of the Recognised List
- The list under Rule 3(ff) of the Karnataka Government Servants (Medical Attendance) Rules, 1963 exists to ensure treatment is taken only from vetted institutions.
No Dispute About Recognition
- Kasturba Medical College Hospital, Manipal, was undisputedly in the recognised list.
- After its official renaming to Kasturba Hospital, Manipal, it remained the same entity.
Failure of Administration
- Authorities failed to update the recognised list despite the hospital’s formal communication.
- Such administrative lapses cannot be used to prejudice employees seeking reimbursement.
Arbitrary Denial
- Denial merely on nomenclature differences is arbitrary and legally unsustainable.
- The legal entity continued to be the same; hence, reimbursement could not be refused
Decision
The Court allowed the writ petition and directed:
Quashing of Rejection Orders:
The impugned orders of July 3, 2024, and August 31, 2024, rejecting the claim were set aside.
Reconsideration of Claim:
Respondents were directed to reconsider the petitioner’s reimbursement application, treating Kasturba Hospital, Manipal, as a continuation of the earlier recognised institution.
Timeline:
Reconsideration must be completed within six weeks of receipt of the order.
Significance of the Ruling
Employee Rights Protected
The ruling protects government employees from being unfairly denied reimbursement due to technicalities unrelated to the quality or legality of the treatment.
Clarification on Hospital Recognition
Recognition pertains to the entity’s services and infrastructure, not merely its name.
Administrative Responsibility
Authorities must update records promptly when hospitals officially change their names. Their failure cannot cause hardship to beneficiaries.
Wider Implications
The decision applies to all cases where government-recognised hospitals undergo rebranding or renaming.
Conclusion
Karnataka High Court’s decision is a crucial affirmation of the principle that substance must prevail over form in administrative matters. By holding that reimbursement cannot be denied solely because of a hospital’s name change, the Court has ensured fairness for government employees who rely on such benefits for medical security.
This ruling emphasises that technical lapses in updating records by the authorities must not override the fundamental rights of employees to access medical facilities and reimbursement for legitimate treatments.
Important Link
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