Introduction:

The case of Ajay Kumar v. State of U.P. and Others came before the Allahabad High Court raising a sensitive yet legally significant question concerning entitlement to ex gratia compensation for deaths allegedly caused by COVID-19 during the peak of the pandemic. The petitioner, Ajay Kumar, approached the Court challenging the decision of the District Magistrate, Firozabad, who had rejected his claim for compensation following the death of his wife. The deceased was working as an Assistant Teacher and had been deputed on election duty in April 2021, a time when the second wave of COVID-19 was at its peak across India. According to the petitioner, his wife had contracted COVID-19 while performing her official duties and subsequently succumbed to the illness. The petitioner sought compensation under the relevant government scheme which provided financial assistance to families of individuals who died due to COVID-19, particularly those engaged in election duty or other public service during the pandemic. However, the claim was rejected on the ground that the petitioner had failed to produce the requisite medical documents, including a positive COVID-19 test report or a death certificate indicating COVID-19 as the cause of death. Aggrieved by this rejection, the petitioner invoked the writ jurisdiction of the High Court, contending that the denial of compensation was unjustified given the prevailing circumstances and the nature of his wife’s duties. The case thus presented an important legal issue regarding the evidentiary requirements for claiming compensation under COVID-19 relief schemes and the extent to which courts can relax such requirements in extraordinary situations.

Arguments of the Petitioner:

The petitioner advanced his case by emphasizing the factual circumstances surrounding the death of his wife and the broader context of the COVID-19 pandemic. It was argued that the deceased had been deployed on election duty during a period when COVID-19 infections were widespread, and therefore, it was highly probable that she had contracted the virus while performing her official responsibilities. The petitioner contended that the absence of a positive RT-PCR or antigen test report should not be treated as fatal to his claim, particularly given the chaos and inadequacies in testing infrastructure during the second wave. He relied on a chest report of the deceased which indicated abnormalities consistent with COVID-19 infection, arguing that such medical evidence, when read in conjunction with the prevailing pandemic conditions, should be sufficient to establish a prima facie case. The petitioner further submitted that the compensation scheme should be interpreted liberally in favour of the claimants, especially in cases involving frontline or essential workers who risked their lives during the pandemic. It was argued that insisting on strict compliance with documentation requirements would defeat the humanitarian purpose of the scheme. Additionally, the petitioner contended that if a person died within 30 days of contracting COVID-19, the requirement of producing all medical reports should be relaxed, as recognized in certain guidelines. He urged the Court to adopt a pragmatic approach and consider the surrounding circumstances rather than insisting on rigid proof. The petitioner essentially sought a relaxation of evidentiary standards, arguing that the combination of duty exposure, medical indications, and timing of death should suffice to establish that the death was due to COVID-19.

Arguments of the Respondents:

The State, on the other hand, defended the rejection of the compensation claim by strictly relying on the provisions of the applicable scheme governing ex gratia payments. It was contended that the scheme clearly stipulates the submission of specific documents as a precondition for granting compensation, including proof of COVID-19 infection, a positive test report, and a death certificate indicating COVID-19 as the cause of death. The respondents argued that these requirements are not merely procedural but are essential to ensure that compensation is granted only in genuine cases where death is conclusively attributable to COVID-19. It was further submitted that the petitioner had failed to produce any such document and had instead relied on a chest report which, according to the State, was insufficient to establish COVID-19 infection. The respondents emphasized that the burden of proof lies on the claimant to demonstrate eligibility under the scheme, and in the absence of requisite evidence, the authorities were justified in rejecting the claim. The State also contended that relaxing the evidentiary requirements in individual cases could lead to misuse of the scheme and open the floodgates for unverified claims, thereby undermining the integrity of the compensation mechanism. It was argued that while the pandemic created extraordinary circumstances, the need for objective and verifiable criteria remained essential to ensure fairness and accountability in the disbursement of public funds.

Judgment:

The Division Bench comprising Justice Ajit Kumar and Justice Garima Prashad, after considering the submissions of both sides, upheld the decision of the District Magistrate and dismissed the writ petition. The Court placed significant reliance on the terms of the compensation scheme, particularly Clause 9, which mandates the submission of three key documents: proof of COVID-19 infection, a positive test report, and a death certificate indicating that the death was caused by COVID-19. The Court observed that these requirements form the foundation for determining eligibility and cannot be dispensed with lightly. While acknowledging that in certain cases where a person dies within 30 days of contracting COVID-19, it may not be possible to produce all medical reports, the Court clarified that even in such situations, a death certificate explicitly mentioning COVID-19 as the cause of death would suffice. However, in the present case, the petitioner had failed to produce either a positive test report or a death certificate attributing the death to COVID-19. The Court held that the chest report relied upon by the petitioner was insufficient to establish that the deceased had contracted COVID-19, as it did not conclusively indicate the presence of the virus. The Court emphasized that for the purpose of awarding compensation under the scheme, it is necessary to establish a clear nexus between the death and COVID-19 infection through reliable medical evidence. The Court further observed that while the humanitarian objective of the scheme is undeniable, it cannot override the need for adherence to prescribed conditions, especially when public funds are involved. In the absence of any documentary proof linking the death to COVID-19, the Court found no infirmity in the decision of the authorities and declined to interfere. The judgment thus reinforces the principle that eligibility for statutory or policy-based benefits must be established in accordance with the criteria laid down, and that courts cannot grant relief on the basis of assumptions or probabilities alone.