The Punjab and Haryana High Court has strongly deprecated the hyper-technical approach of the State of Haryana in denying full medical reimbursement to an 85-year-old retiree who had to undergo an advanced Intravascular Lithotripsy (IVL) procedure to treat heavily calcified coronary artery blocks.

The Court observed that prioritizing a commercial angle over compassion defeats the very essence of a welfare policy. The Court flatly rejected the State's contention that a specialized, life-saving IVL catheter costing ₹3,50,000/- could be reduced to a routine "consumable" capped at a meager ₹1,750/- per day, noting with shock that under the State's hollow approach, it would have happily reimbursed an ineffective conventional angioplasty simply because it was listed in the package schedule, regardless of whether it saved the patient's life.

Consequently, the Court directed the respondent authorities to reimburse the entire medical bill of ₹7,42,630/- along with 6% interest per annum to the legal heirs of the deceased petitioner, while ordering the Director General of Health Services, Haryana, to include the IVL technique within the official package rates and crack down on empanelled hospitals that artificially lower package rates to attract patients.

The Bench of Justice Harpreet Singh Brar observed, "Shockingly, what can be inferred from the respondents' stand is that, had the petitioner undergone conventional angioplasty, regardless of it being ineffective for his heavily calcified coronary blocks, the respondents would have happily reimbursed the same, because it finds mention in the package list, regardless of whether it saved the petitioner's life or not. This Court cannot accept such a hollow approach."

Advocate Madan Lal appeared for the Petitioner, while AAG Saurabh Girdhar appeared for the State of Haryana.

Facts of the Case

The deceased petitioner, an 85-year-old elderly retiree, approached Paras Hospital, Panchkula, on April 19, 2023, exhibiting symptoms indicative of critical Coronary Artery Disease. Upon medical advice, he was admitted to the said hospital on the very same day as an inpatient.

During the course of examination, the attending doctors discovered heavily calcified coronary blocks. Finding that a conventional balloon angioplasty and stenting would be utterly ineffective, the medical team adopted advanced and specialized interventional techniques, namely Rotablation and Intravascular Lithotripsy (IVL), to break the calcified blocks and preserve the life of the patient.

The patient was successfully discharged on April 22, 2023. Subsequently, the hospital raised a total medical bill of ₹7,42,630/-, which included ₹1,35,000/- for the angiography and rotablation packages, and an additional sum of ₹6,02,469.64/- separately charged under the head of medicines and consumables, which prominently featured the specialized IVL catheter costing ₹3,50,000/-.

The petitioner preferred the present Civil Writ Petition under Articles 226/227 of the Constitution of India, seeking a writ of mandamus to direct the respondent authorities to release the entire billing amount of ₹7,42,630/- along with interest at the rate of 18% per annum, or alternatively, to decide upon the legal notice dated November 17, 2023. During the pendency of the proceedings, the original petitioner demised, and his legal heirs were duly impleaded by the orders of the High Court.

Contention of the Parties

The petitioner contended that he was explicitly assured by the hospital authorities that the treatment and diagnostic procedures would be entirely covered under the comprehensive 'Package Rate' stipulated in the state policy. It was further submitted that charging an exorbitant amount separately for medicines and consumables was grossly disproportionate and amounted to an artificial decoupling of essential surgical costs, which was never clearly explained to the elderly retiree.

Per contra, the State vehemently opposed the petition, relying upon the compliance affidavit filed by the Director General of Health Services, Haryana. The State took a rigid stand that all admissible benefits under the prevailing policy dated July 14, 2020, had already been released. It was argued that since Intravascular Lithotripsy (IVL) was a relatively recent technology, it was not enumerated as a recognized package procedure in the government list. Therefore, the State contended that the IVL catheter could only be reimbursed as a non-package "consumable" under Para 4(a)(iii) of the guidelines, which capped reimbursement at a meager ₹1,750/- per day.

The Respondent/Hospital submitted that the hospital charged the beneficiary strictly in accordance with the prescribed rates for the listed packages. It was contended that IVL was a highly specialized modality using unique shockwave-delivering balloon catheters entirely distinct from standard angioplasty. Because the policy did not provide a specific package rate for IVL, the hospital was fully justified in billing the specialized device separately to save the patient’s life.

Observations of the Court

The High Court observed that the factum of medical treatment, the critical nature of the cardiovascular emergency, and the absolute genuineness of the bills raised were entirely undisputed by the parties. The Court noted that the advanced IVL procedure was an absolute medical necessity, as conventional angioplasty would have proven completely futile against the heavily calcified blocks. Consequently, the Court strongly deprecated the hyper-technical approach adopted by the State authorities, holding that denying a valid life-saving claim on such grounds was fundamentally misconceived and unjust.

The Court further observed that a state policy meant to preserve human life could not be allowed to become a procrustean bed of rigid literalism. In a welfare state, medical reimbursement rules must be interpreted as fiscal instruments of social security designed to protect citizens in times of distress.

The Court remarked that when human life hangs in the balance, state policies must bend toward the living rather than standing rigid upon statutory lexicon, and that prioritizing commercial interests over compassion defeated the very essence of a welfare policy.

Relying upon medical literature and scientific journals, the Court observed that Intravascular Lithotripsy is not an isolated or independent procedure, but is legally and medically an advanced modality of endovascular angioplasty itself. The Shockwave IVL device inherently utilizes an angioplasty balloon to deliver acoustic shockwaves to modify plaque. Therefore, the State's attempt to isolate IVL from the broader umbrella of angioplasty procedures was held to be scientifically and legally untenable.

Furthermore, the Court flatly rejected the State's classification of the specialized IVL catheter as a routine "consumable" subject to a ₹1,750/- daily cap. The Court observed that it was utterly irrational and illogical to equate a highly complex, life-saving interventional device costing ₹3,50,000/- with ordinary sundries like gauze, syringes, or dressings. It held that reducing such an essential device to a minor consumable by a stroke of the pen reduced the constitutional right to health to a mere mockery.

The Court ruled that the test for reimbursement must always be what is medically necessary to save a life, rather than what merely finds mention in an administrative list.

The Court observed, "This court cannot countenance the hyper-technical approach adopted by the respondents to deny the reimbursement of a valid medical claim of the treatment which was essential and necessary to preserve the life of the petitioner. Respondents can’t be allowed to refuse to acknowledge an advanced and specialised form of treatment, even though it falls within the same branch of angioplasty and, more critically, was the only course of action available to save the petitioner's life. Compassion has been sacrificed at the altar of technicality. This approach defeats the very purpose of a medical aid policy."

Accordingly, the Court disposed of the writ petition, directing the full reimbursement of the medical bills with 6% interest per annum, while commanding the State to include the IVL technique within its official package rates and establish a regulatory mechanism to check unfair billing practices by empanelled hospitals.

It directed, "Further, the Director General, Health Services, Haryana is directed to verify the package rates of all empanelled hospitals, either himself or through the concerned authorised Civil Surgeon. In case any of the empanelled hospitals are found to be violating the policy, appropriate corrective measures shall be taken, including cancellation of their license. The Director General shall further ensure that the cost of treatment is explained to the patient or their next of kin in a language they are familiar with, instead of merely obtaining signatures on cyclostyled proformas. The practice of artificially lowering package rates to attract patients initially, only to later charge separately for essential procedures, shall not be permitted."

Cause Title: Hukam Singh v. State of Haryana and Ors. [Neutral Citation: 2026:PHHC:69346]

Appearance:

Petitioner: Advocate Madan Lal

Respondents: Additional Advocate General Haryana Saurabh Girdhar, Advocate Ayushi, Advocate Padamkant Dwivedi, Advocate Harsh Aggarwal.

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