In a landmark judgment, the Jharkhand High Court has ruled that individuals seeking reimbursement for mental health treatment cannot be denied on the same grounds as physical illness. The Court directed Bharat Coking Coal Limited (BCCL), a subsidiary of Coal India, to reimburse expenses incurred for the psychiatric treatment of the wife of a retired company executive.
The ruling comes in the case Santosh Kumar Verma v. Bharat Coking Coal Ltd and Others, where the Court emphasized the importance of equitable healthcare treatment for mental illnesses under the Mental Healthcare Act, 2017.
Court’s Interpretation of the Mental Healthcare Act, 2017
Justice Ananda Sen, presiding over the case, referred to Section 21 of the Mental Healthcare Act, 2017, and concluded that there should be no discrimination between the reimbursement of medical expenses for physical and mental illnesses. “From Section 21 of the Mental Healthcare Act, 2017… I conclude that there cannot be any discrimination in the reimbursement of expenses between persons suffering from physical and mental illnesses,” the Court said.
The judge noted that the Act mandates equal treatment for both conditions, ensuring that individuals with mental health conditions are afforded the same rights to medical insurance and reimbursement as those dealing with physical illnesses. Specifically, the Court highlighted Section 21(4) of the Act, which compels insurers to cover mental health treatment in the same manner as physical health treatment.
Conflict with Coal India’s Health Insurance Scheme
The Court’s ruling was prompted by an examination of Coal India’s medical insurance policy—specifically, the Contributory Post Retirement Medicare Scheme for Executives of CIL & its Subsidiaries (CPRMS). The scheme’s Clause 6.3(i) had previously excluded reimbursement for psychiatric treatments, a provision the Court found to be in direct violation of the Mental Healthcare Act.
Justice Sen criticized this exclusion as discriminatory and noted that it was not based on any rational distinction. “The exclusion of psychiatric treatment under CPRMS is in conflict with the provisions of the Mental Healthcare Act,” the Court stated, adding that such a provision could not be upheld under Indian constitutional law.
Legal Implications for State-Run Entities
The Court’s ruling also underscored that Coal India Limited, as a state-owned enterprise, is bound by the provisions of Indian law. Under Article 12 of the Constitution of India, the actions of state-run entities must align with legislation passed by Parliament. Any resolution or provision that conflicts with parliamentary statutes is deemed void.
Although the CPRMS was implemented in 2008—prior to the enactment of the Mental Healthcare Act—the Court held that the law’s provisions supersede any conflicting clauses in pre-existing policies. Consequently, the exclusion of psychiatric treatment was rendered ineffective, aligning the scheme with the statutory mandates of the Act.
Impact on Mental Health Insurance Coverage
The ruling affirms that individuals receiving psychiatric care must receive the same benefits and reimbursements as those receiving treatment for physical health conditions. This decision marks a significant step forward in ensuring equitable access to healthcare for those with mental health conditions in India.
Advocate Gyan Ranjan represented the petitioner, while Advocate Swati Shalini appeared for the State.
The Court’s order not only reinforces the legal framework for mental health care but also ensures that health insurers, including those covering state employees, cannot discriminate against those seeking treatment for mental health issues.
Related Topics
