Writ jurisdiction cannot adjudicate disputed PMJJBY premium-payment facts; petitioner may pursue remedy under Section 22-A.

The petitioner’s husband, Surendra Kumar, maintained a savings account with Punjab National Bank and enrolled under the Pradhan Mantri Jeevan Jyoti Bima Yojana (PMJJBY) in 2015.

Premiums of ₹330 were deducted for the years 2015–16, 2016–17 and 2017–18.

The premium for 2018–19 was not deducted, allegedly because only ₹246.23 was available in the account when the premium was due on 25 May 2018.

Surendra Kumar died on 27 June 2018.

The petitioner thereafter claimed the insured amount of ₹2,00,000, but the claim was rejected by the authorities on 22 May 2019 on the ground that the renewal premium had not been received and the insurance cover had consequently lapsed.

The petitioner challenged the rejection under Article 226 of the Constitution and sought payment of the insurance amount.

Whether the petitioner was entitled to payment of ₹2,00,000 under the PMJJBY despite non-deduction and non-receipt of the renewal premium for 2018–19?

Whether the High Court could adjudicate, in writ jurisdiction under Article 226, the disputed factual question concerning the availability of sufficient balance and the Bank’s alleged failure to deduct the premium?

Whether the petitioner should be relegated to the alternative remedy available under Section 22-A of the Legal Services Authorities Act, 1987?

The Court applied the principle that writ jurisdiction under Article 226 is ordinarily not exercised for adjudicating disputed questions of fact requiring evidentiary examination, particularly where an efficacious alternative remedy is available.

The Court also considered the PMJJBY terms, under which insurance cover operates for one financial year—from 1 June to 31 May—and continuation of cover depends upon payment of the prescribed renewal premium; according to the respondents, non-payment resulted in lapse of the cover.

The Court granted liberty to the petitioner to pursue the remedy contemplated under Section 22-A of the Legal Services Authorities Act, 1987.

The Court noted that the parties presented conflicting factual positions regarding whether the deceased had sufficient funds in his account and whether the Bank was responsible for failing to deduct the ₹330 renewal premium for 2018–19.

Resolution of those questions required examination of the account records and other evidence, which was inappropriate in the writ proceeding.

Since the alleged non-payment of premium directly affected the continuation of the PMJJBY cover and the petitioner had an alternative statutory remedy, the Court declined to determine the merits of the insurance claim under Article 226.

It held that the disputed factual issues could not appropriately be adjudicated in writ jurisdiction and permitted the petitioner to avail the remedy available under Section 22-A of the Legal Services Authorities Act, 1987, in accordance with law.

The writ petition was accordingly disposed of with that liberty, and any pending interlocutory applications were also disposed of.