The Kerala High Court has ruled that compliance with prescribed childhood vaccination schedules is a valid requirement for receiving financial assistance under the central government’s maternity welfare scheme, holding that state financial benefits do not constitute a fundamental right.
Dismissing a challenge against the eligibility criteria of the Pradhan Mantri Matru Vandana Yojana (PMMVY), Justice Bechu Kurian Thomas affirmed that while citizens cannot be physically compelled to immunize their children, the government retains the constitutional authority to set conditional terms for public welfare disbursements.
Locus Standi And Financial Entitlement
The court determined that the petition was not maintainable on procedural grounds. Because PMMVY financial transfers are designated exclusively for mothers and deposited directly into their bank accounts, the court ruled that a father lacks any legally enforceable right to claim the funds on his spouse’s behalf.
Ruling on the constitutional challenge, the bench stated that beneficiaries seeking state grants must strictly meet the established statutory qualifications. Prescribing prerequisites such as basic health safeguards does not violate constitutional guarantees under Article 14 or Article 21, as individuals maintain the choice of whether to apply for conditional assistance.
Background Of The Dispute
The legal challenge was initiated by a 36-year-old resident of Malappuram district following the birth of his daughter on September 3, 2024. Upon requesting the scheme’s benefit, local authorities informed him that disbursement required proof of the child’s vaccination.
The petitioner issued a legal notice on October 23, 2025, claiming that mandatory immunization as a condition for receiving financial aid invaded personal liberty and amounted to indirect coercion. The central government countered that childhood immunization remains voluntary, but non-compliance renders an applicant ineligible for conditional monetary assistance.
Public Health Rules And Legal Precedents
Under the PMMVY Rules notified in December 2022 pursuant to the National Food Security Act of 2013, a one-time grant of Rs 6,000 is payable upon the birth of a second girl child. To qualify, the infant must receive all mandatory immunizations prescribed under the Union Health Ministry’s Universal Immunization Programme within 14 weeks of birth.
The court rejected the petitioner’s reliance on the Supreme Court’s 2022 judgment in the Jacob Puliyel case regarding bodily autonomy. The bench clarified that the precedent dealt specifically with COVID-19 vaccine mandates and did not prohibit reasonable state measures aimed at promoting routine, free childhood immunizations against preventable diseases.
Because the child had not received the required vaccinations within the 14-week window, the court concluded that the eligibility requirements were unmet and dismissed the writ petition.
