Jharkhand HC Rules Against Denying Reimbursement for Mental Health Treatment Expense

Jharkhand HC Rules Against Denying Reimbursement for Mental Health Treatment Expense

The Jharkhand High Court recently upheld that an individual should not be denied reimbursement for expenses related to mental health treatment.

Justice Ananda Sen instructed Bharat Coking Coal Limited, a subsidiary of Coal India Limited, to reimburse the expenses incurred by a retired executive for his wife's psychiatric treatment.

From Section 21 of the Mental Healthcare Act, 2017…I come to the conclusion that there cannot be any discrimination in respect of reimbursement of expenses made by a person suffering from physical illness and mental illness,” the Court held.

The Court noted that the Mental Healthcare Act, 2017 explicitly states that there should be no discrimination between individuals suffering from mental illness and those experiencing any other physical illness.
 
In one line it can be summarized that there cannot be any difference so far as treatment and giving other facilities, between a mentally ill person or a physically ill person. Both of them are kept on the same pedestal so far as treatment is concerned without any discrimination."
 
The Court specifically pointed out Section 21(4) of the Act, which mandates that every insurer must provide medical insurance for the treatment of mental illness on the same terms as for physical illnesses.
 
The aforesaid statutory dictate mandates all the health insurers to make provision for treating mental illness in a similar manner as is done in respect of persons with physical illness. This is also an equality clause, which eliminates discrimination when it comes to medical insurance or reimbursement for treatment of mental illness. By virtue of this statutory provision, there cannot be any exclusion clause to exclude reimbursement of expenses incurred for treating mental ailment or psychiatric treatment in any health insurance policy,” the Court said.
 
The Court issued the order after reviewing Coal India Limited's medical insurance scheme, the Contributory Post Retirement Medicare Scheme for Executives of CIL & its Subsidiaries (CPRMS), in light of the Mental Healthcare Act, 2017.  

It found that Clause 6.3(i) of the CPRMS, which excludes reimbursement for psychiatric treatment expenses, directly contradicts several provisions of the Mental Healthcare Act. The Court held that this exclusion amounts to discrimination without any intelligible differentia.

Coal India Limited and its subsidiary companies are State within the meaning of Article 12 of the Constitution of India. Their action or any resolution, which they adopt cannot be contrary to the provisions of any Statute promulgated by the legislatures, herein the Parliament of India. If any resolution or a part of the resolution, adopted by the Board, is in conflict with any parliamentary legislation, that part of the resolution will become null and void and the same cannot be given effect to,” it added.

The Court observed that the CPRMS was introduced in 2008, long before the enactment of the Mental Healthcare Act, 2017. Consequently, it held that...
 
I hold and declare that after promulgation of Mental Healthcare Act, 2017 and especially taking into consideration Section 21(4) of the Act, exclusion of psychiatric treatment in CPRMS is rendered nugatory."
 
Concluding that patients undergoing psychiatric treatment are entitled to the same benefits as those with physical illnesses, the Court ruled in favor of the petition.
 
Advocate Gyan Ranjan represented the petitioner.

Advocate Swati Shalini represented the State.

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