The Delhi High Court has held that simply describing primary hypertension as a “lifestyle disorder” is not adequate justification to deny disability pension to a retired Indian Air Force (IAF) officer. The Court ruled that such classification, without proper reasoning from the medical board, fails to meet the legal threshold for denying pension benefits.
A division bench of Justices V Kameswar Rao and Manmeet P S Arora passed the judgment on January 19, while dismissing a plea filed by the Central Government challenging an Armed Forces Tribunal (AFT) order that had granted disability pension to the retired officer.
Emphasizing the need for individual assessment, the bench observed,
“It must be noted that lifestyle varies from individual to individual. Hence, a mere statement that the disease is a lifestyle disorder cannot be a sufficient reason to deny the grant of disability pension unless the medical board has duly examined and recorded the particulars relevant to the individual concerned.”
The Court noted that the officer had served the Indian Air Force for over 37 years, having joined in October 1981 and retired in March 2019. While he did not suffer from any disability at the time of recruitment, he was later diagnosed with primary hypertension.
The medical board had described the hypertension as “idiopathic/lifestyle related” and concluded it was neither attributable to nor aggravated by military service, as it was incurred in a peace area. Based on this, the Centre argued against the officer’s eligibility for disability pension.
The High Court, however, took exception to the medical board’s failure to record specific reasons. It noted that while it was not disputed that the officer was medically fit at the time of entry into service, no explanation was offered by the board to justify why the condition could not be attributed to service.
“The position of law in this regard is clear that there is an obligation on the part of the medical board to give reasons for coming to a conclusion. Therefore, the medical board must record the reasons, findings while discharging the onus placed upon it,” the bench stated.
Upholding the decision of the AFT, the bench concluded that there was no error in the tribunal’s reasoning.
“We are of the view that given the facts of this case, the conclusion drawn by the tribunal cannot be faulted. The petition being without any merit is dismissed.”
The judgment is significant in reinforcing the principle that disability pension claims, particularly those involving conditions like hypertension, must be examined based on individual circumstances and supported by well-reasoned findings from the medical authorities.
