Medical Reimbursement Can't Be Denied Because Hospital In Recognized Hospitals List Changed Its Name: Karnataka High Court

The Karnataka High Court has said that medical reimbursement cannot be denied on the ground that a hospital which was earlier recognised by the Government in the list of private hospitals permitted to provide treatment to employees, changed its name.

A single judge, Justice Suraj Govindaraj held thus while allowing a petition filed by Dr. Shivanandappa Doddagoudar an Associate Professor at Government First Grade College Ranebennur Taluka.

It said,

“Medical reimbursement cannot be denied solely due to a change in the name of the hospital, even though it remains the same entity that was previously recognised.”

The petitioner approached the court as the medical reimbursement claim made by him came to be rejected solely on the ground that the hospital from which he availed treatment does not find a place in the Government recognised list of private hospitals eligible for medical reimbursement.

The petitioner argued that the hospital in question 'Kasturba Medical College Hospital, Manipal' was indeed present in the approved list. However, pursuant to a formal request dated 23.03.2021, the hospital sought for change of name to 'Kasturba Hospital, Manipal', in conformity with the registration certificate issued by the Karnataka Private Medical Establishment Authority, Udupi.

Further, despite the name change and the hospital's communication, the updated name was not incorporated in the Government list, resulting in rejection of the reimbursement claim.

The Government advocate argued that only the names of hospitals appearing as is in the approved list can be considered and that deviations, including name changes, cannot be accepted.

The bench noted that the purpose of maintaining a recognised list of private hospitals under Clause (ff) of Rule 3 of the Karnataka Government Servants (Medical Attendance) Rules, 1963, is to ensure that services are availed from vetted and approved institutions. The recognition involves inspection and assessment of the hospital's infrastructure and services.

It noted that 'Kasturba Medical College Hospital, Manipal' was an approved institution and following its name change to 'Kasturba Hospital, Manipal', the hospital submitted a formal application on 23.03.2021 seeking correction in the recognised list. Despite this, the authorities had failed to update the name.

“The hospital remains the same legal entity, and the name change was duly recorded under the Karnataka Private Medical Establishment Act. Denial of reimbursement merely on account of non-updated nomenclature, when the entity remains the same, is arbitrary and legally unsustainable. The respondent authorities were obligated to verify the request and update the recognised list after following the due procedure. Their failure to do so cannot prejudice the petitioner,” the Court held.

Allowing the petition the court directed the Executive Director Suvarna Arogya Suraksha Trust to reconsider the petitioner's application for medical reimbursement, taking into account the change in the name of Kasturba Medical College Hospital, Manipal to Kasturba Hospital, Manipal, in accordance with applicable procedure.

Appearance: Advocate Harshawardhanagouda Patil for Petitioner.

AGA Sharad V Magadum for Respondents.

Citation No: 2025 LiveLaw (Kar) 308

Case Title: DR. SHIVANANDAPPA DODDAGOUDAR And THE STATE OF KARNATAKA & Others

Case No: WRIT PETITION NO. 106571 OF 2025.

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