Rajumon T.M. v. Union of India
Background
The appellant enrolled in the Indian Army as a sepoy in 1988 and, after more than nine years of service, was discharged in 1998 after being diagnosed with schizophrenia. An Invalidating Medical Board opined that the disease was neither attributable to nor aggravated by military service and was constitutional in nature, so his disability pension claim was rejected. His subsequent appeals (to an appellate committee, through a Member of Parliament, and finally to the Armed Forces Tribunal) were all unsuccessful.
Decision Breakdown
The Supreme Court held that under the applicable Entitlement Rules, a disease manifesting during service carries a presumption that it is attributable to or aggravated by service, and this presumption can only be displaced by cogent, well-reasoned medical findings, not a bare conclusion. It found the Medical Board's opinion lacked the necessary supporting reasons to rebut this presumption, so the denial of pension could not be sustained. However, given that 27 years had passed since discharge, the Court declined to send the matter back for fresh medical reconsideration. Instead, it left the discharge order undisturbed but directed that disability pension be granted with immediate effect and all attendant benefits, though without full back-arrears (limited to the last three years).
Lesson Learnt
Soldiers benefit from a statutory presumption that a disease which arises during service is connected to that service; the burden falls on the military authorities to give cogent, reasoned grounds to rebut this presumption: an unexplained medical opinion is not enough to deny a disability pension.