CAT - ['Jabalpur']
Employment and Labour LawSocial Security and Pensions

Delayed medical reimbursement does not, by itself, create entitlement to interest.

HARI DUTT SEETHA vs DEFENCE

CAT - ['Jabalpur']JUDGMENT: September 21, 20262 MIN READSOURCE JUDGMENT
Delayed medical reimbursement does not, by itself, create entitlement to interest.. HARI DUTT SEETHA vs DEFENCE. CAT - ['Jabalpur']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a retired Junior Works Manager, filed the Original Application seeking reimbursement of ₹13,80,532 incurred for the COVID-19 hospitalisation of himself and his wife in 2021.

Source reference: p.2

The respondents contended that ₹6,27,837 had already been reimbursed by the Additional Director, CGHS, on 22 July 2022, and that the remaining ₹7,52,695 had been refunded by Metro Hospital on 22 August 2024.

Source reference: p.2

The applicant’s counsel was absent on two successive dates, including the date of decision, and the applicant did not deny receipt of the entire amount in his rejoinder.

Source reference: p.2–3

The claim for interest on the delayed reimbursement also remained for consideration.

Source reference: p.3
02

Issues

1. Whether the applicant continued to have any surviving claim for reimbursement when the entire claimed amount of ₹13,80,532 had already been disbursed to him.

Source reference: p.2–3

2. Whether the applicant was entitled to interest on the delayed reimbursement of medical expenses.

Source reference: p.3–4
03

Law Applied

The Tribunal applied the principle that an employee’s enforceable right in respect of medical expenses is ordinarily confined to reimbursement of the verified principal amount and that delay in such reimbursement does not, by itself, create an entitlement to interest.

Source reference: p.3

It relied on Om Prakash Garg v. State of Punjab & Ors., 1997 SCC (L&S) 479, wherein the Supreme Court held that it is neither proper nor expedient to direct the State to pay interest on delayed medical reimbursement, since the claim is subject to verification and the employee’s right is limited to reimbursement of the amount properly incurred.

Source reference: p.3–4
04

Reasoning

The Tribunal found that the respondents had established payment of both components of the applicant’s claim—₹6,27,837 reimbursed through CGHS and ₹7,52,695 refunded by the hospital—thereby exhausting the principal claim of ₹13,80,532.

Source reference: p.2–3

Since the applicant did not dispute receipt of the full amount in his rejoinder, no substantive reimbursement dispute survived.

Source reference: p.3

Applying Om Prakash Garg, the Tribunal further held that delayed payment did not independently justify an award of interest, particularly where the underlying medical expenses had already been verified and reimbursed.

Source reference: p.3–4
05

Holding

The Tribunal answered both issues against the applicant. It held that the entire medical reimbursement claimed had already been paid and that no entitlement to interest arose merely because of delay in disbursement.

Accordingly, Original Application No. 865 of 2023 was dismissed, with no order as to costs.

Source reference: p.4
CAT - ['Jabalpur']

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HARI DUTT SEETHAvsDEFENCE

CAT - ['Jabalpur'] · September 21, 2026

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