Introduction:

The Bombay High Court, Kolhapur Circuit Bench, in Sunil Shankar Mohite vs Union of India (Writ Petition 7359 of 2023) delivered a significant judgment reinforcing the protective intent of welfare schemes framed during the Covid-19 pandemic and ensuring that frontline health workers are not denied benefits on technical or procedural grounds. The Division Bench comprising Justice Ravindra Avachat and Justice Ajit Kadethankar examined a plea filed by Sunil Mohite, the husband of late Rekha Mohite, who served as a nurse in the Police Hospital at Sangli during the Covid-19 pandemic. Rekha Mohite was actively involved in treating suspected Covid-19 patients, primarily police personnel who were continuously exposed to the virus while maintaining law and order during the pandemic. During her service, she contracted Covid-19 on April 21, 2021 and succumbed to the infection on April 24, 2021. Following her death, the petitioner sought compensation under the Pradhan Mantri Garib Kalyan Package, a welfare scheme introduced by the Union Government to provide financial security to families of healthcare workers who lost their lives while combating the pandemic. However, the claim was rejected by authorities on the ground that the Police Hospital at Sangli was not officially categorised, enlisted, or requisitioned as a Covid-19 treatment centre under the scheme guidelines. Aggrieved by this rejection, the petitioner approached the High Court seeking directions to grant compensation, arguing that his wife’s contribution as a frontline health worker could not be ignored merely because of administrative classification of the hospital where she was posted. The case raised crucial questions regarding the interpretation of welfare schemes, the scope of protection extended to frontline workers, and the constitutional principles governing equality and fairness in state action.

Arguments:

The petitioner argued that the rejection of compensation was arbitrary, unjustified, and contrary to the objectives of the Pradhan Mantri Garib Kalyan Package which was specifically designed to provide financial relief to families of health workers who sacrificed their lives while performing Covid-related duties. The petitioner submitted that Rekha Mohite was undeniably a health worker who was on active duty in a hospital environment dealing with suspected Covid-19 patients during the peak of the pandemic. It was emphasized that police personnel, who formed the primary group of patients treated at the Police Hospital Sangli, were among the most vulnerable sections exposed to the virus due to their continuous field duties. The petitioner contended that the nature of the work performed by Rekha Mohite placed her at equal risk as any health worker serving in a designated Covid treatment centre and therefore denying compensation solely based on hospital categorisation amounted to discrimination and violation of Article 14 of the Constitution. It was further argued that the original Union Government order introducing the compensation scheme did not impose any requirement that the health worker must be serving in a hospital specifically enlisted or requisitioned as a Covid treatment centre. The petitioner submitted that the hospital where Rekha Mohite was posted was performing preliminary Covid screening and treatment functions, after which patients were referred to larger Covid treatment facilities. The petitioner maintained that such preliminary treatment centres played a crucial role in pandemic management and exposed staff to equal risk of infection. The petitioner also relied on the certification provided by competent authorities confirming that Rekha Mohite contracted Covid-19 while on duty and had been continuously working for fourteen days prior to her death, thereby fulfilling the essential eligibility conditions under the scheme. On the other hand, the respondents including the Union of India, State Authorities, and insurance company argued that the scheme required strict adherence to eligibility criteria and that compensation could be granted only when the deceased health worker was posted in a hospital officially requisitioned or designated for Covid treatment. The respondents submitted that a State-appointed committee had created categories of hospitals to streamline implementation of the scheme and to prevent misuse or over-expansion of financial liability. It was contended that since the Police Hospital Sangli was not included in the list of requisitioned Covid treatment centres, services rendered there could not be classified as Covid-related services within the meaning of the scheme. The respondents further argued that policy decisions regarding scheme implementation fell within administrative discretion and judicial interference in such matters would disrupt governance and financial planning. They maintained that the categorisation was introduced to maintain uniformity and prevent ambiguous claims. The respondents also contended that expansion of the scheme’s scope beyond its intended administrative framework would impose additional financial burden on the exchequer and create precedent for claims beyond the policy’s original scope.

Judgment:

After carefully considering the submissions and examining the scheme framework, the Bombay High Court rejected the authorities’ interpretation and held that the denial of compensation was contrary to the very object and purpose of the Pradhan Mantri Garib Kalyan Package. The Court observed that the scheme was a benevolent welfare measure intended to provide comprehensive protection to frontline health workers who risked their lives during an unprecedented global health crisis. The Bench noted that the original Union Government order introducing the scheme did not impose any requirement that the hospital where the deceased worked must be enlisted or requisitioned as a Covid treatment centre. The Court held that introducing such a restrictive interpretation would frustrate the scheme’s purpose and defeat its humanitarian objective. The judges observed that Rekha Mohite was undisputedly working as a nurse at the Police Hospital Sangli during the peak of the Covid-19 pandemic and was actively treating suspected Covid patients. The Court further noted that the Police Hospital functioned as a preliminary treatment centre where infected or suspected patients were examined and then referred to specialised Covid treatment centres, thereby exposing the staff to equal risk of infection. The Court acknowledged that police personnel, who were frequently treated at the hospital, were constantly exposed to the virus due to their frontline duties and could have transmitted infection to healthcare workers including Rekha Mohite. The Bench emphasized that eligibility for compensation under the scheme required proof that the deceased was a health worker who contracted Covid-19 while performing duty, and these conditions were fully satisfied in the present case. The Court strongly criticized the authorities for introducing an additional requirement regarding hospital categorisation, terming it an extraneous and illogical condition not supported by the scheme’s framework. The Bench held that such classification created artificial barriers and undermined the welfare intent of the policy. The Court also took judicial notice of the functioning of various preliminary health centres during the pandemic where suspected Covid patients were initially screened and treated before being referred to larger hospitals. The judges observed that healthcare workers at such preliminary centres were equally susceptible to infection and could not be excluded from compensation benefits merely due to administrative categorisation of institutions. The Court further held that rejecting the petitioner’s claim on such technical grounds amounted to arbitrary classification and violated Article 14 of the Constitution which guarantees equality before law. The Bench described the rejection order as lacking pragmatic reasoning and failing to reflect the humanitarian spirit underlying the scheme. The Court also noted the extremely short gap between detection of infection and death which further supported the conclusion that Rekha Mohite contracted the virus while performing her official duties. Observing that frontline healthcare workers made immense sacrifices during the pandemic, the Court stated that welfare schemes must be interpreted liberally to ensure that deserving beneficiaries are not denied relief due to bureaucratic technicalities. Consequently, the Court allowed the petition and directed the concerned authorities to process and release compensation under the Pradhan Mantri Garib Kalyan Package to the petitioner within sixteen weeks. The judgment stands as a strong reaffirmation of constitutional principles of fairness, equality, and protection of frontline workers and highlights the judiciary’s role in ensuring that welfare schemes serve their intended humanitarian purpose rather than being restricted by rigid administrative interpretations.