Reasoned Medical-Board Findings as a Condition Precedent to Denial of Disability Pension – A Commentary on Rajumon T.M. v. Union of India (2025 INSC 644)

1. Introduction

The Supreme Court’s decision in Rajumon T.M. v. Union of India inaugurates an important doctrinal shift in Indian military pension jurisprudence. The appellant, a former Sepoy invalided out of service in 1998 due to schizophrenia, challenged the Armed Forces Tribunal’s refusal to award disability pension. At the heart of the dispute lay the Medical Board report, which branded his illness a “constitutional personality disorder” and, without recording any supportive reasoning, concluded it was “neither attributable to, nor aggravated by, military service.”

While earlier Supreme Court precedent had counselled strong deference to Medical Board opinions, the present Bench (Justices Abhay S. Oka & Nongmeikapam Kotiswar Singh) draws a crucial distinction between a bare conclusion and a reasoned conclusion. The Court ultimately sets aside the pension denial and declares that where a Medical Board offers no discernible reasoning, the consequential refusal of disability benefits is unsustainable. This commentary dissects the ruling, its doctrinal underpinnings, and its likely systemic impact.

2. Summary of the Judgment

The appellant served in the Army from 17-11-1988 to 18-05-1998 and was invalidated for schizophrenia (30 % disability).
The Medical Board left multiple columns in Form AFMSF-16 blank, yet opined the disease was “constitutional” and not linked to service.
All appellate channels within the Army and the Armed Forces Tribunal upheld the rejection of disability pension.
The Supreme Court re-examined Regulations 173 & 423 of the Pension Regulations for the Army, 1961, and Appendix II.
Key finding: Regulations mandate that the Medical Board “specify reasons” for its opinion; a mere ipse dixit is insufficient.
Because no reasons existed, the discharge order remained, but the denial of disability pension was quashed. The Court directed:
- Grant of disability pension prospectively with all attendant benefits.
- Payment of arrears limited to the preceding three years.
Crucially, the Court did not remand the matter for a fresh Board—citing 27 years’ delay and the benevolent object of pension schemes.

3. Analysis

3.1 Precedents Cited and Their Treatment

Union of India v. Keshar Singh (2007) – Held that Medical Board opinion is ordinarily conclusive regarding attributability. The present Court accepts the principle but emphasises that conclusiveness presupposes a “reasoned” opinion.
Union of India v. Surinder Singh Rathore (2008); A.V. Damodaran (2009); Jujhar Singh (2011); Talwinder Singh (2012) – These cases reinforced deference to Medical Boards. The Bench distinguishes them on facts: those Boards had recorded detailed reasons, whereas the present Board left critical sections blank.
Narsingh Yadav v. Union of India (2019) – Reiterated the liberal construction of pension regulations. The present ruling extends that liberality by requiring robust procedural adherence.
Kerala High Court Full Bench in Baby v. Union Of India (2003) – Considered but ultimately overshadowed by the new principle demanding detailed Board reasoning.

3.2 Legal Reasoning

1. Regulatory Mandate: Regulation 423(d) expressly states that the Medical Board “will specify reasons for their opinion.” The Court treats this as a mandatory, not directory, obligation.
2. Doctrine of Beneficial Construction: Disability pension provisions being socio-welfare legislation, any ambiguity must tilt in favour of the soldier (Maniben Maganbhai Bhariya, 2022).
3. Burden of Proof: Where a soldier is found medically fit at enrolment and the disease surfaces later, the onus shifts to the State to rebut the deeming fiction that it arose in service (Reg. 423(e)).
4. Natural Justice & Reasoned Decision-making: A non-speaking Medical Board opinion deprives the serviceman of the opportunity to rebut or explain and undermines the pension-sanctioning authority’s evaluation. This violates Article 14 jurisprudence on arbitrary state action.
5. Schizophrenia’s Special Profile: The Court re-quotes its earlier discussion in Veer Pal Singh (2013) to stress that the cognitive debilitation inherent in schizophrenia warrants heightened judicial solicitude.

3.3 Impact of the Judgment

Procedural Overhaul: Medical Boards must henceforth produce detailed, cogent reasons when declaring a disability “constitutional” or “not connected with service”. Failure will vitiate downstream administrative orders.
Evidentiary Balance Re-calibrated: The long-standing principle of deference survives but is now contingent upon demonstrable reasoning—what the Court calls the difference between a conclusion and the reasons for it.
Increased Pension Entitlement: Ex-servicemen previously denied benefits on cryptic medical opinions can invoke this precedent for review or fresh claims.
Administrative Training & Documentation: Armed Forces Medical Services will need new checklists/templates ensuring Part II & III of AFMSF-16 are filled comprehensively.
Judicial Economy: By refusing remand after nearly three decades, the Court signals that prolonged delays will militate against further fact-finding and favour immediate relief.
Cross-Pollination: While the case concerns military pensions, the principle that “expert bodies must furnish reasons” can influence adjudication under labour-law medical boards, insurance medical evaluations, and social-security schemes.

4. Complex Concepts Simplified

Disability Pension: A composite benefit (service element + disability element) payable to personnel invalidated from service with ≥20 % disability that is either “attributable to” or “aggravated by” military service.
Schizophrenia: A chronic psychiatric disorder marked by distorted thinking and perception; symptoms include hallucinations, delusions, disorganised speech, and cognitive impairment.
Constitutional Disease: An ailment considered inherent to an individual’s physiology or genetics, not triggered by external service conditions.
Attributability vs. Aggravation:
- Attributable – disease/injury caused by service conditions.
- Aggravated – pre-existing condition worsened by service.
Benefit of Doubt: Where evidence is evenly balanced, Regulations direct that judgement favour the claimant, especially in field-service cases.
Medical Board (AFMSF-16): A tri-service statutory body that records medical findings and recommendations regarding invalidation.
Reasoned Decision: A decision that discloses an intelligible chain of logic linking facts, law, and conclusion; a requirement flowing from Article 14 (non-arbitrariness).

5. Conclusion

Rajumon T.M. marks a crucial course-correction in military pension law. The Court does not dilute the authority of Medical Boards; instead, it insists that such authority be exercised transparently, with articulated reasons that can withstand judicial scrutiny. In doing so, the judgment harmonises deference to expert opinion with constitutional demands of fairness and the welfare-oriented character of disability pensions. Going forward, any denial of pension resting on a non-speaking medical opinion will be vulnerable to challenge, fostering both administrative accountability and substantive justice for India’s servicemen and women.