Legal Review and Analysis of Pradeep Arora & Ors vs Director Health Department Govt of Maharashtra & Ors 2025 INSC 1420
Case Synopsis
Pradeep Arora & Ors. v. Director, Health Department, Govt. of Maharashtra & Ors. (2025 INSC 1420)
Insurance for Pandemic Warriors – Interpreting “Requisition” in the PM Garib Kalyan Package
Synopsis: The Supreme Court interpreted the scope of “requisition” under the Pradhan Mantri Garib Kalyan Yojana insurance scheme for health workers who died during COVID-19 duties. It held that a notice issued under the Epidemic Diseases Act, compelling a private doctor to keep his clinic open during lockdown, amounted to legal “requisition” of services. The Court rejected a narrow, bureaucratic interpretation and emphasized a humanitarian reading of the scheme to honor frontline workers’ sacrifices.
1. Heading of the Judgment
Case Name: Pradeep Arora & Ors. v. Director, Health Department, Govt. of Maharashtra & Ors.
Citation: 2025 INSC 1420
Court: Supreme Court of India
Judges: Justice Pamidighantam Sri Narasimha & Justice R. Mahadevan
Date of Judgment: December 11, 2025
2. Related Laws & Sections
Epidemic Diseases Act, 1897: Sections 2, 3, 4
Maharashtra Prevention and Containment of COVID-19 Regulations, 2020: Regulation 10
Indian Penal Code, 1860: Section 188
Pradhan Mantri Garib Kalyan Yojana (PMGKY) Package: Insurance Scheme for Health Workers Fighting COVID-19 (Order dated 28.03.2020)
3. Judgment Details
A. Facts of the Case
The case concerned Dr. Bhaskar Surgade, a private medical practitioner in Navi Mumbai.
During the COVID-19 lockdown, the Navi Mumbai Municipal Commissioner issued a notice dated 31.03.2020 under the Epidemic Diseases Act and State COVID Regulations, directing Dr. Surgade to keep his clinic open, failing which an FIR under IPC Section 188 would be filed.
Dr. Surgade tested positive for COVID-19 in June 2020 and died.
His wife (Appellant No. 3) claimed insurance under the PM Garib Kalyan Package, which provided ₹50 lakh to health workers “requisitioned” for COVID duties.
The claim was rejected on the ground that his services were not “specifically requisitioned” for COVID-19 work.
The Bombay High Court upheld the rejection, leading to an appeal before the Supreme Court.
B. Issues Before the Supreme Court
Whether the notice directing a private doctor to keep his clinic open during the pandemic constitutes “requisition” under the PMGKY insurance scheme?
Whether a hyper-technical interpretation of “requisition” should defeat the beneficial purpose of the scheme meant for frontline health workers?
C. Ratio Decidendi (Court’s Reasoning)
Context of Pandemic Laws: The Court noted that the Epidemic Diseases Act and State Regulations were invoked precisely to compel services of health professionals in an emergency.
Meaning of “Requisition”: The Court held that requisition need not be a formal appointment letter. In the pandemic context, a legal direction under the Act requiring a doctor to keep his clinic operational amid a health crisis amounts to constructive requisition.
Purpose of the Insurance Scheme: The PMGKY scheme was a welfare measure to honor and secure frontline workers. A narrow, pedantic interpretation would defeat its objective.
Evidence of Duty: The Court clarified that while “requisition” is established as a legal fact, individual claimants must still prove that the death occurred while performing COVID-related duties based on evidence.
4. Core Principle & Analysis
Beneficial Interpretation of Welfare Schemes in Emergencies
The Supreme Court emphasized that laws and schemes enacted during a national crisis must be interpreted in a manner that fulfills their humanitarian intent, not defeated by procedural technicalities.
Key Takeaways
Legal Compulsion = Requisition: A directive issued under the Epidemic Diseases Act, backed by penal consequences for non-compliance, is a de facto requisition of services.
Judicial Recognition of Sacrifice: The Court refused to accept the State’s argument that only doctors in designated COVID hospitals were covered. The pandemic required every available medical professional to serve.
Balancing Rights & Proof: While adopting a liberal interpretation of “requisition,” the Court left it to the authorities to verify factual evidence of COVID-19 duty and death in individual cases.
5. Final Outcome & Directions
Appeal Partly Allowed.
The Supreme Court declared that the notice dated 31.03.2020 amounted to requisition under the PMGKY scheme.
The matter was remitted for reconsideration of the insurance claim based on evidence of duty and death.
Individual claimants must prove with evidence that the death occurred while performing COVID-19-related responsibilities.
6. MCQs Based on Judgment
Q1. In Pradeep Arora v. Director, Health Dept., what did the Supreme Court hold regarding the term “requisition” under the PM Garib Kalyan insurance scheme?
A) It requires a formal written contract from the government.
B) It includes a legal directive under the Epidemic Diseases Act compelling a doctor to keep his clinic open during lockdown.
C) It applies only to government hospital staff.
D) It is limited to doctors working in COVID-designated hospitals.
Q2. What was the primary reason the Supreme Court rejected the State’s narrow interpretation of the insurance scheme?
A) Because the doctor was a relative of the appellant.
B) Because the scheme was ambiguously drafted.
C) Because a humanitarian welfare scheme during a pandemic should be interpreted beneficially to honor frontline workers.
D) Because the State failed to produce evidence.