Medical reimbursement is limited to textually authorized benefits; silent or non-enumerated treatments/devices are not enforceable rights.

The petitioner, a Senior Engineer at Oil India Limited (OIL), was diagnosed with Sensorineural Hearing Loss (SNHL) and Tinnitus

Based on medical advice from Apollo Hospital, the petitioner sought financial assistance for a Tinnitus Masker (costing Rs. 4,09,995/-) and subsequent referral for specialized Neuro-Modulation Therapy abroad

OIL rejected these requests, citing a lack of provision in the company’s rules, though they approved a standard hearing aid capped at Rs. 50,000/-

The petitioner proceeded with treatment abroad on personal leave and subsequently filed this writ petition seeking reimbursement, future treatment costs, and damages for alleged medical negligence by company doctors

1. Whether the OIL Employees’ Medical Attendance Rules, 2018, provide a legally enforceable right for the reimbursement of a Tinnitus Masker and medical treatment undertaken abroad

2. Whether the absence of a specific provision in the 2018 Rules mandates the application of the Central Services (Medical Attendance) Rules, 1944, to grant the requested relief

3. Whether claims for damages and independent enquiries into medical negligence can be adjudicated under Article 226 of the Constitution

The Court interpreted the OIL Employees’ Medical Attendance Rules, 2018, specifically Rule 8.0 regarding the scope of benefits and Rule 9.0 regarding exclusions

It applied the principle that when an interpretation clause uses both "means" and "includes," it provides an exhaustive definition, as established in *Hamdard (Wakf) Laboratories v. Deputy Labour Commissioner* [(2007) 5 SCC 281] and *P. Kasilingam v. P.S.G. College of Technology* [1995 Supp (2) SCC 348]

The Court also invoked the legal maxim *expressio unius est exclusio alterius* (the mention of one thing implies the exclusion of others) to determine that specifically listing "hearing aids" implied the exclusion of other auditory devices like Tinnitus Maskers

The Court reasoned that Rule 8.0. (xi) and (xvi) of the 2018 Rules are restrictive; by explicitly capping hearing aid costs and listing specific artificial appliances in Annexure-VI, the rules deliberately omitted Tinnitus Maskers

Regarding foreign treatment, the Court found that Rule 11.1 (x) limits referrals to hospitals "in the country"

Rule 13.2 only permits foreign medical reimbursement for employees on official tours via insurance, which did not apply to the petitioner's personal visit

Furthermore, the Court held that Rule 15.0 (which allows the application of Central Government Rules) is discretionary and requires prior approval from the Director (HR & BD), which was not granted

Finally, the Court determined that the claim for damages involved disputed questions of fact and tortious liability, which cannot be resolved in writ jurisdiction without expert evidence

The Court clarified that while the right to health is fundamental, it does not mandate reimbursement beyond the fiscally calibrated boundaries of a codified employer scheme

The prayer for damages and enquiry was refused as unsuitable for Article 226 proceedings, though the petitioner was granted liberty to approach an appropriate civil forum for compensation