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Supreme Court of India 2025-12-11 partly_allowed

Pradeep Arora & Ors vs Director, Health Department, Government of Maharashtra & Ors

Bench: 2 — Pamidighantam Sri Narasimha, R. Mahadevan

In Brief

During the COVID-19 pandemic, India's government issued regulations and notices directing private doctors to remain available for duty under threat of criminal prosecution. When Dr. Surgade, a private practitioner, died of COVID-19, his widow sought ₹50 lakh insurance under the Pradhan Mantri Garib Kalyan Yojana (PMGKY) Scheme. The government and High Court rejected her claim, arguing his services were never formally requisitioned. The Supreme Court allowed the appeal in part, holding that statutory notices issued under the Epidemic Diseases Act, 1897, backed by threat of criminal prosecution, constituted valid 'requisition' for insurance purposes. However, claimants must still prove the deceased died while performing COVID-19-related duties. The Court rejected formalistic interpretation in favour of a purposive approach recognizing pandemic realities.

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Administrative Law Constitutional Law Public Health Law COVID-19 Pandemic Response Insurance Law Social Security Schemes Statutory Interpretation Emergency Powers Requisition of Services

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