Hypertension and Diabetes Cannot Be Treated as ‘Lifestyle Diseases’ to Deny Disability Pension, Bombay High Court Rules

 

The Bombay High Court reaffirmed that conditions such as hypertension and diabetes cannot simply be categorised as lifestyle diseases to deny disability pension to armed forces personnel when such conditions are attributable to, or aggravated by, military service. The Division Bench of Chief Justice Shree Chandrashekhar and Justice Gautam Ankhad upheld the judgment of the Armed Forces Tribunal, which had granted disability pension to Army and Navy personnel who developed medical conditions including diabetes, hypertension, spondylitis and other ailments during their service and were invalided out or left in a low medical category due to these conditions. The High Court noted that disability pension is not a bounty granted at the discretion of the government but a valuable right that confers economic security to personnel whose physical and mental capabilities diminish over time as a result of service. It emphasised the broader purpose of pension jurisprudence and disability pension in particular, which is to ensure socio-economic justice by recognising the sacrifices of military personnel and by providing financial support when they are no longer able to serve due to medical conditions developed during service.

In the petitions filed by the Union Government challenging various orders of the Armed Forces Tribunal, the central contention of the government and its medical boards was that diseases like obesity, diabetes and hypertension were constitutional or lifestyle disorders, which should not qualify for disability pension on that basis alone. The government argued that such conditions, especially if detected while personnel were posted in peace stations, were not attributable to or aggravated by military service and therefore did not merit pensionary benefits. The High Court rejected this argument, holding that the relevant rules did not intend to exclude conditions merely because they were labelled as lifestyle diseases. It observed that proving direct causation between service conditions and specific diseases like hypertension would often be impossible, and that personnel should not be deprived of benefits on narrow interpretations that undermine the object of the disability pension scheme. The court pointed out that diseases recognised in military entitlement rules, including hypertension, are acknowledged as conditions that can qualify for disability pension if they occur or are aggravated during service.

The bench highlighted that it is the duty of the adjudicating tribunal to interpret beneficial provisions liberally rather than to construe them in a way that curtails entitlements. It reiterated that pension rights, once earned by service and by development of disabling conditions during service, cannot be denied based on technical or restrictive interpretations that run counter to the purpose of the rules. The court also dismissed the Union Government’s contention that the opinion of expert medical boards was final and unfettered; it clarified that tribunals have the jurisdiction to assess whether the medical board’s findings properly reflect the applicable legal standards and whether they reasonably connect the disabling condition to service.

In upholding the Armed Forces Tribunal’s orders, the High Court noted multiple cases where disability pension had been granted on the grounds that diseases such as diabetes mellitus, primary hypertension, dyslipidemia, obesity and others were either attributable to service conditions or aggravated during service. The tribunal had assessed, in each case, whether the medical condition emerged or worsened in the course of the individual’s service, and had found that these conditions met the criteria for disability pension under the relevant entitlement rules. Personnel who had served in operational and peace areas, and who had developed or seen an aggravation of these conditions, were found entitled to disability pension benefits accordingly.

The High Court also clarified that the onus does not shift entirely to the personnel to prove a disease’s service connection in every case; rather, the government must demonstrate a clear and cogent reason to displace the presumption that a disease manifesting during service is attributable to or aggravated by that service. The court’s decision reflects a recognition that many medical conditions, including diabetes and hypertension, can be influenced by the rigours and stresses of military life, and that denying pensionary benefits on the simplistic ground that they are “lifestyle diseases” would undermine the protective purpose of disability pension provisions.

By dismissing the writ petitions filed by the Union Government and affirming the tribunal’s orders, the Bombay High Court has reinforced the principle that conditions arising or worsening during military service, even if commonly characterised as lifestyle disorders, cannot be excluded from disability pension eligibility simply on that basis. The court’s judgment underscores the importance of a purposive and liberal interpretation of pension entitlement rules that honour the service and sacrifice of armed forces personnel by ensuring they receive the pensionary support to which they are justly entitled when medical conditions disable them from further service.

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