LexRAJUMON T.M. versus UNION OF INDIA & ORS.
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[2025] 5 S.C.R. 1279 : 2025 INSC 644 Rajumon T.M. v. Union of India & Ors. (Civil Appeal No. 998 of 2025) 07 May 2025 [Abhay S. Oka and Nongmeikapam Kotiswar Singh,* JJ.] Issue for Consideration Whether in case of discharge of a serviceman from the Indian Army, on the ground of medical invalidation and consequent denial of disability pension, the burden of proof lies on the serviceman or the concerned department? Whether the existence of a causal link between the service conditions and the disability in order to claim disability pension or the nature of the service area? Whether a non-reasoned order of the Medical board be relied upon to grant or deny of disability pension? Headnotes† Petitioner, after serving in Indian Army as a sepoy for 9 years, was discharged on ground of medical invalidation as per medical board’s (“Board”) opinion for having developed Schizophrenia after being 5 years into the service – Board opined – During the onset of the said disease, Petitioner was serving at a peace station; hence the said disease was not attributable to or aggravated by the military service conditions – Petitioner challenged the said discharge before first appellate committee and subsequently before the Armed Forces Tribunal but it was unsuccessful – Being aggrieved, Petitioner approached Hon’ble Supreme Court. Proving causal linkage between service conditions and disability is must for seeking disability pension; nature of service area immaterial: Held: The principles governing grant of disability pension are as follows: (i) a causal connection between the disablement and military service must be proved for its attributability to be considered; * Author 1280 [2025] 5 S.C.R. Supreme Court Reports (ii) all evidence (direct and circumstantial), material on record must be considered in this respect; (iii) benefit of reasonable doubt will be given to the claimant and must be construed more liberally in case of field service; (iv) type of service area i.e., peace service area or field/active service area is immaterial in determining the attributability of the disability on service conditions; (v) a disease causing discharge will ordinarily be deemed to have arisen in service if no note of it was made at the time of the individual’s acceptance for service in the armed forces; (vi) if as per medical opinion of medial board / medical officer (backed by reasons), disease could not be detected on medical examination before acceptance for service, the disease will not be deemed to have arisen during service; (vii) the opinion of the Medical Board/medical officer, regarding actual cause of the disability or death and the circumstances in which it originated will be regarded as final; (viii) question of attributability to service and attendant circumstances will be decided by the pension sanctioning authority; and (ix) CO will furnish concerned medical reports to the medical officer/ medical board as the case may be – Tribunal rightly culled out the legal principles from various judgments of this Court but the application thereof to the facts of this case was improper – As per Regulation 173 read with Appendix II (particularly clause 4) of Pension Regulations for the Army, 1961 and Regulation 423 of the Regulations for Medical Services for Armed Forces 1983. [Paras 9-17] Medical Board’s opinion was not backed by reasons and thus was arbitrary and against mandatory applicable provisions: Held: As per the original medical records, Petitioner was not suffering from Schizophrenia when he joined the service – Some parts of Petitioner’s medical records were left blank and hence the board’s conclusion that Petitioner’s disease was constitutional personality disorder is erroneous because the board did not consider the medical records in the first place – The Board also failed to provide reasons for its opinion that Petitioner’s disease was a constitutional personality disorder – Providing reasons was “crucial, critical, decisive and necessary” rather than being a formality in terms of Regulation 423(d) as pension sanctioning authority had to determined grant/denial of disability pension based on such reasons as board’s opinion was final – In present case, board’s opinion was arbitrary for being devoid of reasons – Liberal approach must be adopted while interpreting provisions of disability [2025] 5 S.C.R. 1281 Rajumon T.M. v. Union of India & Ors. pension (Reliance placed on M
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