Case Title : Pradeep Arora & Ors. v. Director, Health Department, Govt. of Maharashtra & Ors
Citation : 2025 INSC 1420
Date : 11.12.2025
Hon’ble Supreme Court Bench – Justices PS Narasimha and R Mahadevan
The Supreme Court judgment, Pradeep Arora & Ors. v. Director, Health Department, Govt. of Maharashtra & Ors., delivered on December 11, 2025, provides a crucial interpretation of the Pradhan Mantri Garib Kalyan Yojana (PMGKY) insurance scheme for healthcare workers during the COVID-19 pandemic.The case originated from a claim by the wife of a deceased private medical practitioner, Dr. B.S. Surgade, for the ₹50 lakh insurance cover under the PMGKY scheme. The claim was rejected by authorities arguing that the doctor was a private practitioner whose services had not been formally and explicitly “requisitioned” for COVID-19 duty as required by the scheme. The Bombay High Court upheld the rejection, concluding that the NMMC’s notice was merely a general encouragement to keep dispensaries open, not a specific “requisitioning” or “drafting” of services.
The Supreme Court while rejecting the narrow approach of Hon’ble High Court Of Bombay, upheld :
- The term ‘requisioning’ didn’t essentially include a formal, individual letter of appointment during the pandemic situation.
- The Court held that the NMMC’s compulsory order, issued under the Epidemic Diseases Act and backed by the threat of criminal prosecution, constituted a sufficient “requisition” of the doctor’s services.
- While settling the legal interpretation of “requisition,” the Court issued a clear directive that the applicability of the insurance policy still rests on the factual evidence. The claimant must establish, with “credible evidence,” that the deceased lost their life while performing a COVID-19-related duty
