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Introduction
In Chandra Choor Singh v. State of U.P. and Others, decided on 28 March 2026, the Allahabad High Court (Lucknow Bench) “read down” Rule 16 of the Uttar Pradesh Government Servant (Medical Attendance) Rules, 2011 to allow legal heirs of a deceased government servant to claim medical reimbursement where the servant died during or after treatment. The Division Bench of Justice Alok Mathur and Justice Amitabh Kumar Rai held that restricting reimbursement claims solely to the “beneficiary” (as narrowly defined in the Rules) was arbitrary and violative of Article 14 of the Constitution.
Background
Rule 16 of the UP Government Servant (Medical Attendance) Rules, 2011 requires that a reimbursement claim be submitted by the “beneficiary.” The question arose: what happens when a government servant incurs medical expenses during treatment but dies before submitting the claim? Under a strict reading, the claim would fail because a deceased person cannot file it.
Facts
The petitioner was the legal heir of a government servant who had incurred significant medical expenses during treatment. The government servant died during or after the course of treatment. When the petitioner (as legal heir) submitted a claim for reimbursement of the medical expenses, the authorities rejected the claim on the ground that Rule 16 restricted the right to claim reimbursement to the defined “beneficiary,” and the petitioner was not a “beneficiary” under the Rules.
The Court’s Holdings
Reading Down Rule 16
The Court read down Rule 16 to include legal heirs within its scope, so that where a beneficiary dies or becomes incapacitated during treatment, the legal heirs may step into the beneficiary’s shoes to claim reimbursement.
Article 14 Violation
The Court held that restricting reimbursement claims solely to the defined “beneficiary” — such that the claim perishes with the death of the servant — was arbitrary and violative of Article 14 (right to equality) of the Constitution. The medical expenses were legitimately incurred during the servant’s lifetime for treatment to which the servant was entitled. There was no rational basis for denying reimbursement merely because the servant died before filing the claim.
Succession Certificate — Practical Observation
The Court also addressed a practical hurdle. Authorities had contended that the legal heir required a succession certificate to claim reimbursement, and that the certificate issued by the Tehsildar was subject to a monetary ceiling lower than the reimbursement amount.
The Court held that where there is no genuine dispute as to the identity of the legal heir, the monetary limit on a Tehsildar-issued succession certificate cannot bar a reimbursement claim of a higher value. A person cannot be compelled to obtain a full succession certificate from a civil court (which involves significant time and expense) where no one disputes their status as legal heir.
Practical Implications
- Legal heirs can now claim medical reimbursement that was due to a government servant who died during or after treatment, without the claim being rejected on the technical ground that only the “beneficiary” could file it.
- The succession certificate hurdle is eased — where there is no genuine dispute about heirship, authorities cannot insist on a full civil court succession certificate for processing reimbursement.
- Families should ensure they retain all original medical bills, prescriptions, and hospital records, as these will be required to support the reimbursement claim.
Key Statutory Provisions
- Rule 16, Uttar Pradesh Government Servant (Medical Attendance) Rules, 2011 — Procedure for medical reimbursement claims.
- Article 14, Constitution of India — Right to equality and equal protection of the laws.
- Indian Succession Act, 1925 — Succession certificates (Sections 370–390).
Useful Resources
- Law Trend — Allahabad HC Reads Down Rule 16
- The Print — Legal Heirs Can Claim Medical Reimbursement
- Indian Kanoon — Search Indian case law and statutes
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