Medical Boards must record cogent reasons and causative factors to rebut the presumption of service-related disability attributability.

The Respondent was enrolled in the Indian Army on January 20, 1966, and was superannuated on May 31, 2005

In December 2004, a Release Medical Board (RMB) assessed the Respondent with "Non-Insulin Dependent Diabetes Mellitus" (NIDDM) at 30% disability for life

The RMB classified the disability as "Neither Attributable Nor Aggravated" (NANA) by military service, labeling it a "metabolic disorder"

The Respondent’s initial claim was rejected in 2005

After a 12-year delay, the Respondent filed a statutory appeal, which was rejected in 2017/2018 on grounds of delay and the "peace station" onset of the disease

The Armed Forces Tribunal (AFT) subsequently granted the Respondent the disability element of pension at 30% (rounded to 50%) for life, effective from the date of discharge, restricting arrears to three years prior to the filing of the Original Application (OA)

The Union of India challenged this order via the present writ petition

1. Whether the Respondent is entitled to disability pension despite being superannuated and the RMB categorizing the condition as NANA

2. Whether the Entitlement Rules of 1982 or 2008 govern the Respondent’s claim for disability benefits

3. Whether the lack of causative factors in the RMB's opinion renders the denial of attributability legally unsustainable

4. Whether the writ petition is barred by delay and laches given it was filed 2.5 years after the impugned order

The court applied the Entitlement Rules for Casualty Pensionary Awards to Armed Forces Personnel, 1982, noting they govern claims for personnel retired prior to 2008

It relied on the principle established in Dharamvir Singh v. Union of India (2013), which creates a presumption of sound physical and mental condition at the time of enrollment if no disability was recorded at entry

Under Bijender Singh v. Union of India (2025) and Rajumon T.M. v. Union of India (2025), the Military Establishment bears the burden of proof to rebut this presumption with a "reasoned medical opinion" that enlists specific causative factors, rather than mere conclusions like "metabolic disorder" or "constitutional"

Furthermore, per Union of India v. Col. Balbir Singh (Retd.), the onset of a disease at a "peace station" is not a valid ground to deny attributability

The Court rejected the Petitioners' argument that the Entitlement Rules, 2008 applied, clarifying that since the Respondent retired in 2005, the 1982 Rules (which favor the officer with a presumption of attributability) were applicable

The Court found that the RMB failed to provide any "cogent reasons" or "causative factors" to support its conclusion that NIDDM was a purely metabolic disorder unrelated to service

The Court noted that the RMB itself admitted the disability did not exist prior to entry and was not due to the Respondent's negligence

Consequently, the "NANA" finding was deemed an unreasoned conclusion that failed to rebut the legal presumption of attributability

The Court further observed that the Petitioners' challenge was significantly delayed, as the writ was filed 2.5 years after the AFT's order without explanation, violating the expected four-month compliance/challenge window

The Court held that the Respondent is entitled to the disability element of pension at 30%, rounded off to 50% for life

It affirmed that in the absence of a reasoned medical opinion identifying causative factors for the disease, the disability is presumed attributable to military service

Additionally, the Court held the petition was barred by delay and laches

No costs were awarded