HAFED Claimant’s Pre-October 14, 2025 Treatment Stays Under ₹2 Lakh Reimbursement Cap As P&H HC Sets Aside Full-Payout Order

In brief

The question

1. Whether the amendment removing the Rs. 2,00,000 ceiling applied retrospectively to medical treatment undertaken before it came into force, by reason of the Board’s earlier resolution.

The court held

The Court allowed HAFED’s appeal to the extent of setting aside the Single Judge’s direction for uncapped reimbursement; the Rs. 2,00,000 ceiling governed the respondent’s pre-amendment treatment claim.

It also directed

If the respondent’s relaxation application was still pending, the competent authority was directed to decide it by a reasoned and speaking order within three months of receiving a certified copy of the judgment.

The appeal was disposed of on those terms.

01Facts

Respondent No. 1 sought reimbursement for medical treatment undertaken before 14 October 2025, when Rule 16(8)(2) of the Haryana State Cooperative Supply and Marketing Federation Limited (Common Cadre) Rules, 1988 capped indoor-treatment reimbursement at Rs. 2,00,000.

¶ 6, 13

The Board of Administrators had resolved on 23 November 2020 to remove the ceiling, but the Registrar approved the proposal on 30 September 2025 and the amendment was implemented by notification dated 14 October 2025.

¶ 8

The Single Judge allowed the respondent’s writ petition and directed reimbursement without the ceiling, treating the Registrar’s approval as relating back to the Board’s resolution.

¶ 1, 9

HAFED appealed.

The respondent also submitted that an application seeking relaxation of the applicable rule remained undecided.

¶ 16–18

02Issues

i.1. Whether the amendment removing the Rs. 2,00,000 ceiling applied retrospectively to medical treatment undertaken before it came into force, by reason of the Board’s earlier resolution.

¶ 8–13

ii.2. Whether the respondent’s pending application for relaxation of the reimbursement ceiling was required to be considered and decided by the competent authority.

¶ 16–18

03Law Applied

Rule 16(8) of the 1988 Rules governed medical reimbursement: sub-rule (1) provided for reimbursement in accordance with instructions issued by the Registrar from time to time, and sub-rule (2), before amendment, imposed an overall Rs. 2,00,000 ceiling for indoor treatment of retired employees and their dependent family members.

¶ 6

The Court applied the principle that an amendment to a rule operates from the date it is brought into force unless retrospective operation is expressly provided; a prior recommendation or resolution does not itself create an enforceable right where the required approval has not yet been granted.

¶ 10–13

The Court also referred to the 1988 Rules’ provisions on relaxation, requiring prior approval of the Board of Directors and the Registrar, and on interpretation by the Registrar.

¶ 11, 16–18

04Reasoning

The governing rule on the date of treatment imposed the reimbursement ceiling. The Board’s 2020 resolution was only a proposal; the Registrar approved it in 2025, and the resulting amendment was implemented on 14 October 2025. As there was no demonstrated provision or express direction making the amendment retrospective, the Court held that the later amendment could not displace the ceiling applicable when the respondent received treatment.

¶ 8–13

Separately, if the respondent’s relaxation application remained pending, the competent authority had to decide it under the applicable rules by a reasoned order.

¶ 17–18