High Court of KeralaSingle JudgePetition allowed; petitioner entitled to full m...

V.T. THOMAS v Union of India and Others

Case / Petition Number:WP(C) No. 32842 of 2022

Case Details & Bench

Court
High Court of Kerala
Hon'ble Judges
  • Raja Vijayaraghavan V.
Judgment Date
2023-10-05
Court Decision / Holding
This writ petition is allowed. The petitioner is entitled to medical reimbursement of the expenses evidenced by Exhibits P3, P6, P10, and P14. The respondents are directed to disburse the same after deducting food expenditures from the bills within three months from the date of receipt of a copy of this judgment.
Final Disposition
Petition allowed; petitioner entitled to full medical reimbursement with deduction of meal expenses;支付within 3 months.

Parties to the Case

Appellants / Petitioners

  • V.T. Thomas

Respondents

  • Union of India
  • Director General Central Government Health Scheme
  • Additional Director Central Government Health Scheme

Legal Representation & Advocates

Counsels for Petitioners

  • • S. Gopalakrishnan Nair

Counsels for Respondents

  • • Manu S., DSG of India

Case Synopsis & Summary

The petitioner, a septuagenarian and retired Assistant Sub-Inspector of the Border Security Force, approached the High Court seeking full reimbursement of medical expenses incurred for treatment of Acute Calculus Cholecystitis in 2022 under CGHS. After initial emergency care at St. Thomas Hospital Chethipuzha, the petitioner underwent a Percutaneous Cholecystostomy, later laparoscopic procedures, and additional care at Mar Sleeva Medicity, with the treatment spanning January–June 2022. He contends total outlay of Rs. 6,28,155, but only Rs. 3,45,916 was reimbursed because the treating facilities were in a non-empanelled private hospital. He asserts the constitutional right to health, arguing that the ultimate medical decision rests with the treating doctor and that denying reimbursement on technical grounds or hospital-naming restrictions is unjust, particularly given his travel constraints (approximately 100 km to CGHS empanelled facilities) and urgent nature of his illness. The respondents contend that CGHS reimbursement is permissible only through Wellness Centres or empanelled hospitals, with eligible amounts calculated according to CGHS rates; they rely on procedures and grievance mechanisms. The Court considered medical records, policy frameworks, and cited authorities on healthcare rights, ultimately holding that the petitioner is entitled to medical reimbursement for the relevant expenses, subject to deducting food costs, and directed payment within three months from the date of judgment.

Provisions of Law Cited

Constitution of India, Article 21 (Right to life and health)Constitution of India, Articles 39(e), 39(f), 41, 42CS(MA) Rules, 1944O.M. dated 05.06.1998 (Note 2 appended to Rule 1)O.M. dated 20.08.2004CGHS Guidelines/Policy (Central Government Health Scheme)

Legal Doctrines & Maxims

  • Right to health is an integral part of the right to life (Bandhua Mukti Morcha v. Union of India)
  • The treating doctor has the prerogative to decide treatment; right to medical claim cannot be denied merely because the hospital is not listed (Shiva Kant Jha v. Union of India)
  • Equality of health benefits to retirees (Union of India v. Shankar Lal Sharma)
  • Self-preservation of life as part of the right to life (Surjit Singh v. State of Punjab)
  • Government obligation to provide health facilities to government servants (State of Punjab v. Mohinder Singh Chawla)

Submissions & Arguments

Contentions of Appellants / Petitioners

The petitioner's counsel argued that a septuagenarian must have access to medical treatment in emergencies without being unduly limited by the hospital's inclusion in a CGHS empanelment. The doctor’s assessment and urgent need for treatment justified care outside empanelled facilities. Records (emergency certificates, discharge summaries, inpatient bills) show ongoing treatment from January to June 2022 across multiple hospitals. The right to health is a fundamental aspect of life under Article 21, and the apex court has held that treatment decisions rest with medical professionals, not bureaucratic gatekeeping. Denying full reimbursement on technical grounds would undermine the constitutional right to health, especially where records substantiate the treatment. The petitioner asks for reimbursement of the full amount incurred, deducting only permissible food expenses, with justice and humane consideration as guiding principles, in line with established precedents.

Contentions of Respondents

The respondents contended that CGHS reimbursement is contingent on treatment within CGHS-empanelled hospitals or Wellness Centres and that the final admissible amount follows CGHS rates. They argued that the petitioner bypassed CGHS procedures by seeking non-empanelled private hospital care, and hence full reimbursement cannot be granted. They cited Sh Shiva Kant Jha for the principle that the doctor decides treatment and that eligibility requires genuine medical necessity, but asserted that policy and grievance channels must be followed. They maintain that the claim was settled at CGHS rates and emphasize the client’s obligation to utilize CGHS channels and the Wellness Centre network.

Cited Precedents (6)

Case NameCitationTreatmentExplanation
Shiva Kant Jha v. Union of India2018) 16 SCC 187PositiveCited to support that government employees have a right to medical care and that medical treatment decisions rest with doctors; denial on hospital naming alone would be unjust.
State of Punjab and Others v. Mohinder Singh ChawlaAIR 1987 SC 1260PositiveUsed to reinforce that right to health is integral to right to life and that government bears responsibility to reimburse medical expenditures.
Union of India v. Shankar Lal SharmaCWP No. 4621 of 2011 (dated 28.12.2015)PositiveCited for equality of health benefits to retirees and non-discrimination in health facilities.
Bandhua Mukti Morcha v. Union of India1984) 3 SCC 161PositivePara-mount principle that health and dignified living are essential rights protected under Article 21.
Surjit Singh v. State of Punjab1996) 2 SCC 336PositiveSupport for self-preservation as part of the right to life, reinforcing humane treatment in medical contexts.
State of Punjab v. Mohan Lal Jindal2001 KHC 3937PositiveCited to bolster authority on health entitlement and medical treatment outside standard hospital networks.

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Extracted Judgment Text

Exact text extracted from official judgment records.

# **`IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT`** ## **`THE HONOURABLE MR. JUSTICE RAJA VIJAYARAGHAVAN V THURSDAY, THE 5[TH] DAY OF OCTOBER 2023 / 13TH ASWINA, 1945 WP(C) NO. 32842 OF 2022`** ## **`PETITIONER/S:`** ``` V.T.THOMAS AGED69YEARS S/O.LATE.THOMASJOSEPH,ASSISTANTSUBINSPECTOR (BORDERSECURITYFORCE)(RETD.),VADAKKEKUTTUHOUSE, - KOOTHRAPPALLY,KOTTAYAMDT,PIN686540 BYADVC.S.GOPALAKRISHNANNAIR ``` ## **`RESPONDENT/S:`** ``` 1UNIONOFINDIA REPRESENTEDBYITSSECRETARY, MINISTRYOFHEALTHANDFAMILYWELFARE, - NEWDELHI,PIN110001 2DIRECTORGENERAL CENTRALGOVERNMENTHEALTHSCHEME, - NIRMANBHAVAN,NEWDELHI,PIN110001 3ADDITIONALDIRECTOR CENTRALGOVERNMENTHEALTHSCHEME,MOSQUELANE, - KESAVADASAPURAM,THIRUVANANTHAPURAM,PIN695004 BYADVMANUS.DSGOFINDIA ``` ``` THISWRITPETITION(CIVIL)HAVINGCOMEUPFORADMISSIONON 05.10.2023,THECOURTONTHESAMEDAYDELIVEREDTHEFOLLOWING: ``` WP(C) No. 32842 of 2022 2 ## **JUDGMENT** The petitioner herein is a septuagenarian. He had worked as Assistant Sub Inspector in the Border Security Force (BSF) and had attained superannuation on 31.8.2010. He is spending his retired life at Koothrapally in Changanacherry Taluk, Kottayam District. The residence of the petitioner is at a distance of about 100 Kms from Ernakulam. 2. The petitioner states that he has enrolled himself in the Central Government Health Scheme (CGHS), and he has been issued with a CGHS card. He asserts that on 10.1.2022, he suffered serious pain in his abdomen and also had a fever. His family members rushed him to St. Thomas Hospital, Chethipuzha, which is at a distance of 12 Kms from his residence. He was found to be suffering from Acute Calculus Cholecystitis. After treating him conservatively, he was discharged on 17.1.2022. He has placed before this Court the emergency certificate, the discharge summary as well as the Inpatient Service Bill issued by the hospital. After being discharged, the petitioner again suffered serious abdominal pain and body temperature and had to be rushed to the very same hospital. On examination, the concerned medical officer advised WP(C) No. 32842 of 2022 3 the petitioner to undergo a Percutaneous Cholecystostomy. He underwent the said procedure and was discharged on 12.2.2022. Ext.P6 is the Inpatient Service Bill and Ext.P7 is the Discharge Summary of the petitioner herein. He states that after undergoing the surgical procedure, he felt acute pain again on 20.2.2022. To secure better treatment facilities, the petitioner was rushed to Mar Sleeva Medicity at Palai, which had better facilities than the former hospital. He had to undergo Laparoscopic Cholecystostomy for Acute Calculus Cholecystitis, and he was discharged on 4.3.2022. It was found that there was a mass formation around the gallbladder with the colon and duodenum plastered around the gallbladder. This fact would be evident from the Ext.P10 discharge bill as well as the Ext.P13 letter and treatment records issued by the Mar Sleeva Medicity Hospital. The wound got infected, and it was in the said circumstances that the petitioner was again rushed to the Mar Sleeva Hospital on 30.5.2022, and he was discharged on 11.6.2022. This fact would be evident from the Ext.P14 bill as well as the Ext.P15 covering letter. 3. The petitioner, in the said circumstances, approached the 3rd respondent and sought reimbursement. He asserted that he had spent a total sum of Rs.6,28,155/-. However, on the premise that the petitioner had not secured treatment in an empanelled hospital, only a sum of Rs.3,45,916/- was WP(C) No. 32842 of 2022 4 granted by way of reimbursement. Being aggrieved, the petitioner has approached this Court seeking the issuance of directions to the respondents to reimburse the entire amount of bills and after deducting the food expenditure and other expenses from the bills. 4. A statement has been filed by the DSGI for and on behalf of the respondents. What is stated in the statement is that the petitioner was admitted to a non-empanelled Private Hospital, which is a course that could not be followed. If the petitioner had secured treatment in an empanelled Hospital, then the CGHS would have considered his medical reimbursement, and admissible amounts would have been paid as per the CGIS Rates. It is further stated that the petitioner ought to have taken the advice of the Wellness Centre or been admitted to any of the CGHS empanelled Hospitals. The claim raised by the petitioner was, however, settled at CGHS rates after deducting the expenses incurred by the petitioner in addition to the CGHS rates. 5. An additional statement has also been filed, as directed by this Court, wherein the calculation sheet in respect of the claim preferred by the petitioner for the period of treatment has been placed on record. It is stated that the claim for medical reimbursement preferred by the petitioner was considered by the respondents, and eligible amounts were sanctioned and disbursed. It is WP(C) No. 32842 of 2022 5 also stated that as the petitioner secured treatment in a private non-empanelled Hospital, he is not entitled for full reimbursement. 6. Sri. C.S. Gopalakrishnan, the learned counsel appearing for the petitioner, submitted that the stand adopted by the respondents cannot be sustained. The learned counsel would invite the attention of this Court to the treatment records, and it is pointed out that the ailment suffered by the petitioner is a syndrome of fever and lymphocytosis associated with the gallbladder. The petitioner is residing at a place called Koothrappally within the limits of Changanacherry Taluk, and in order to secure treatment from an empanelled hospital, he would have to travel at least 100 Kms to Ernakulam. The learned counsel also submits that the pain associated with the gallbladder inflammation suffered by the petitioner was so intense that it would not be possible for the petitioner even to travel a few distance. It is submitted that, after securing treatment in the initial stage at St. Thomas Hospital, he felt that his pain would not recur, but he was wrong. The learned counsel submits that the respondents have no case in their counter affidavit that the petitioner had not undergone treatment or that the ailments suffered by the petitioner are not correct. The learned counsel would then invite the attention of this Court in WP(C) No. 32842 of 2022 6 **Shiva Kant Jha vs. Union of India[1]** , and it is submitted that the Apex Court has held that the Government employee during his lifetime or after his retirement is entitled to get the benefits of medical facilities and no fetters can be placed on his rights. The learned counsel would also refer to the law laid down in the **State of Punjab and Others v. Mohan Lal Jindal[2] ,** and it is submitted that the stand adopted by the respondents without appreciating the nature of the ailments suffered by the petitioner herein is clearly unsustainable. According to the learned counsel, the respondents are obligated to reimburse the expenses since the right to health is an integral part of the right to life. The learned counsel would also refer to the judgment rendered by the Division Bench of Himachal Pradesh High Court in **Union of India Vs. Shankar Lal Sharma** (CWP No.4621 of 2011 dated 28.12.2015) to substantiate his contention. 7. In response, the learned Central Government Counsel submitted that the petitioner ought to have visited the Wellness Centre and thereafter secured treatment in a hospital approved by the CGHS. In the case on hand, the petitioner secured treatment in a non-empaneled hospital, which according to the respondents, is against the procedure as well as the scheme of the CGHS **.** He would point out that the ailments suffered by the petitioner are not such that he > 1 [W.P (Civil) No.694 of 2015] > 2 [2001 KHC 3937] WP(C) No. 32842 of 2022 7 could have bypassed the procedure under the scheme. It is further submitted that in terms of the directions issued by the Apex Court in **Shiva Kant Jha** (Supra), the Central Government has constituted a high powered committee for the grievance redressal of CGHS beneficiaries pertaining to the medical treatment. It is submitted that instead of approaching the high powered committee for redressal of his grievance, there is no justification on the part of the petitioner in approaching this Court. 8. I have considered the submissions advanced and have gone through the records. 9. In the case on hand, the medical records produced before this Court disclose that the petitioner was suffering from Acute Calculus Cholecystitis. He initially went to a local hospital with intense pain and fever. Acute cholecystitis is a condition where the gallbladder becomes inflamed due to the presence of gallstones. The intensity of pain associated with acute cholecystitis is typically described as severe. There would be constant pain in the upper right abdomen or right upper quadrant. The pain may also radiate to the back or shoulder. It is often accompanied by other symptoms such as fever, nausea, vomiting, and jaundice. Acute cholecystitis is considered as a medical emergency, and delaying treatment can lead to serious complications, such as a perforated gallbladder, WP(C) No. 32842 of 2022 8 which can be life-threatening. A person experiencing the symptoms of acute cholecystitis will have to seek medical attention immediately. Waiting for a day or two, especially when there is evidence of mass formation or complications involving nearby organs like the colon and duodenum, is not advisable. Prompt medical evaluation and treatment, which may include antibiotics and potentially surgery to remove the gallbladder, are crucial to prevent further complications and alleviate the pain. In the case on hand, it is clear that it was when the petitioner felt intense pain that he had gone to the hospital. 10. In the context of the fact situation presented in this case, the question is whether the action on the part of the petitioner to seek treatment in a non-empaneled hospital could be treated as a reason to deny a claim for medical reimbursement to an employee if he is otherwise entitled to the same. A similar question was considered by the Apex Court in **Shiva Kant Jha v. Union of India[3]** . The Apex Court held that the right to medical claim could not be denied merely because the name of the hospital is not included in the Government Order. Paragraph No. 13 of the judgment reads as under: 13) It is a settled legal position that the Government employee during his life time or after his retirement is entitled to get the benefit of the medical facilities and no fetters can be placed on his rights. It is acceptable to > 3 (2018) 16 SCC 187 WP(C) No. 32842 of 2022 9 common sense, that ultimate decision as to how a patient should be treated vests only with the Doctor, who is well versed and expert both on academic qualification and experience gained. Very little scope is left to the patient or his relative to decide as to the manner in which the ailment should be treated. Speciality Hospitals are established for treatment of specified ailments and services of Doctors specialized in a discipline are availed by patients only to ensure proper, required and safe treatment. Can it be said that taking treatment in Speciality Hospital by itself would deprive a person to claim reimbursement solely on the ground that the said Hospital is not included in the Government Order. The right to medical claim cannot be denied merely because the name of the hospital is not included in the Government Order. The real test must be the factum of treatment. Before any medical claim is honoured, the authorities are bound to ensure as to whether the claimant had actually taken treatment and the factum of treatment is supported by records duly certified by Doctors/Hospitals concerned. Once, it is established, the claim cannot be denied on technical grounds. Clearly, in the present case, by taking a very inhuman approach, the officials of the CGHS have denied the grant of medical reimbursement in full to the petitioner forcing him to approach this Court. ## 11. The Apex Court has observed in the **State of Punjab and Others** **v. Mohinder Singh Chawla[4]** that the right to health is integral to the right to life, and the Government has a constitutional obligation to provide health facilities to its servants. If a Government servant suffers an ailment that requires treatment at a specialized approved hospital and the Government servant > 4 AIR 1987 SC 1260 WP(C) No. 32842 of 2022 10 ## undergoes treatment therein, it is the duty of the State to bear the expenditure incurred by the Government servant. It would be pertinent to extract the relevant observations: 10. It is contended for the State that though the Government had granted ex post facto sanction through the Medical Board and permitted the patient to undergo treatment outside the State with the policy, for reimbursement of medical expenses incurred and the medical treatment taken in the hospital to the government servant/pensioners or dependants, as per rules, the Government has imposed a condition to pay room rent at the rates charged by the AIIMS for stay in the hospital. The reimbursement will be given at those rates. The Government, therefore, is not obliged to pay the actual expenses incurred by the patient while taking the treatment as in-patient in the hospital, for rent. 11. We are unable to agree with the stand taken by the Government. It is seen that the Government had decided in the proceedings dated 8-10-1991 to reimburse the medical expenditure incurred by the Punjab Government employees/pensioners and dependants on treatment taken abroad in a private hospital. It is stated in paragraphs 2 and 3 that the Government has prepared a list of those diseases for which the specialised treatment is not available in the Punjab Government hospitals but it is available in certain identified private hospitals, both within and outside the State. It was, therefore, decided to recognise these hospitals for treatment of the diseases mentioned against their names in the enclosed list for the Punjab Government employees/pensioners and their dependants. The terms and conditions contained in the letter under reference would remain applicable. The Government can, however, revise the list in future. The name of the disease for which the treatment is not available in the Punjab WP(C) No. 32842 of 2022 11 Government hospitals is shown as Open Heart Surgery and the name of the private hospital is shown as Escorts Heart Institute, New Delhi as one of the approved hospitals/institutions. Thus, for open heart surgery or heart disease the Escorts Heart Institute is an authorised and recognised institution by the Government of Punjab. Consequently, when the patient was admitted and had taken the treatment in the hospital and had incurred the expenditure towards room charges, inevitably the consequential rent paid for the room during his stay is an integral part of his expenditure incurred for the treatment. Consequently, the Government is required to reimburse the expenditure incurred for the period during which the patient stayed in the approved hospital for treatment. It is incongruous that while the patient is admitted to undergo treatment, he is refused the reimbursement of the actual expenditure incurred towards room rent and is given the expenditure of the room rent chargeable in another institute whereat he had not actually undergone treatment. Under these circumstances, the contention of the State Government is obviously untenable and incongruous. We hold that the High Court was right in giving the direction for reimbursement of a sum of Rs 20,000 incurred by the respondent towards the room rent for his stay while undergoing treatment in Escorts Heart Institute, New Delhi. ## 12. In **Bandhua Mukti Morcha v. Union of India[5]** , it was observed by the Hon’ble Supreme Court that Articles 21, 39(e), (f), 41, and 42 are meant to ensure a life with human dignity. The right to live with human dignity enshrined under Article 21 derives its life breath from the Directive Principles of State Policy and particularly clauses (e) and (f) of Article 39 and Articles 41 and > 5 (1984) 3 SCC 161 WP(C) No. 32842 of 2022 12 42, and at the least, therefore, it must include protection of the health and strength of workers, men, and women, and of the tender age of children against abuse, opportunities and facilities for children to develop in a healthy manner and in conditions of freedom and dignity, educational facilities, just and humane conditions of work and maternity relief. These are the minimum requirements that must exist in order to enable a person to live with human dignity, and no State—neither the Central Government nor any State Government—has the right to take any action which will deprive a person of the enjoyment of these basic essentials. 13. In **Union of India and another v. Shankar Lal Sharma** (CWP No.4621 of 2011 dated 28.12.2015), a Division Bench of the Himachal Pradesh High Court had occasion to hold as follows: 52. It is the prime responsibility of the State Government to protect the health and vigour of retired Government officials, this being their fundamental right under Article 21, read with Articles 39(3), 41, 43, 48A of the Constitution of India. The steps should be taken by the State to protect the health, strength, and vigour of the workmen. No providing of postretirement medical care to retired Government official in a city not covered by CGHS at par with in-service employee would result in a violation of Article 21 of the Constitution of India. Moreover, employees need medical care most WP(C) No. 32842 of 2022 13 after their retirement. The State cannot call its own actions as wrong. We have clarified and explained O.M. dated 20.08.2004, and it is made clear that all the Central Government pensioners residing in non-CGHS areas would be covered either under the CS(MS) Rules, 1944 or CGHS as per their option to be sought for by the Central Government. In order to avoid litigation, this judgment shall apply to all the retired Government officials residing in non-CGHS areas. There should be equality of health benefits to retirees as well in their evenings of life. There cannot be any discrimination while extending the social benefits to in-service and retirees. It is the prime responsibility of the State to protect the health of its workers. In view of the phraseology employed in O.M. dated 05.06.1998, Note 2 appended to Rule 1 is read down to extend the benefit of CS(MA) Rules, 1944 to retired Government officials residing in non-CGHS areas to save it from unconstitutionality and to make it workable. The higher Courts have to evolve new interpretive tools in changing times. The neo capitalism may concentrate wealth in the hands of a few persons, which would be contrary to the philosophy of the Constitution of India. Right to health is a human right. The action of the petitioner-Union of India, not to reimburse the medical bills to the respondent and also not giving option to him and similarly situate persons residing in a city not covered under CGHS as per O.M. dated 5.6.1998 to either opt for CGHS Scheme or CS(MA) Rules, 1944, is illegal, arbitrary, capricious, discriminatory, thus, violative of Articles 14, 16 and 21 of the Constitution of India. The decision in matters pertaining to the health of the employee should be taken with utmost humane approach. WP(C) No. 32842 of 2022 14 14. In **Surjit Singh v. State of Punjab[6]** , it was held by the Hon’ble Supreme Court in paragraph 11 of the judgment that self-preservation of one's life is the necessary concomitant of the right to life enshrined in Article 21 of the Constitution of India, fundamental in nature, sacred, precious and inviolable. The importance and validity of the duty and right to self-preservation have a species in the right of self-defense in criminal law. The above observation was made in the context of medical treatment and reimbursement, more particularly in respect of a Government servant. 15. In the instant case, the petitioner had undergone treatment for Acute Calculus Cholecystitis. The petitioner is a septuagenarian, and one of the essential characteristics of the ailment is acute abdominal pain. The respondents also do not have a case in which they have issued directions/orders/circulars/ information to their servants informing them that if they require urgent intervention due to a life-threatening disease for which treatment cannot be prolonged, they can seek treatment at a specified/named hospital in the District. A person experiencing a serious ailment that requires prompt assistance cannot choose between hospitals. The medical records plainly show that the petitioner was suffering from serious pain, and he could not have travelled to either a > 6 (1996) 2 SCC 336 WP(C) No. 32842 of 2022 15 wellness center or an empanelled hospital situated hundreds of kilometers away. The situation would have been different if the medical intervention could have been postponed to a later date. The legal position is clear that government employees, whether during their service or after retirement, have the right to medical facilities. The decision on how a patient should be treated rests with the treating doctor. The focus should be on the actual treatment received, supported by certified records. Denying reimbursement on technical grounds is unjust. It is trite that the right to health is inextricably linked to the right to life protected by Article 21 of the Indian Constitution. The directions issued by the respondents do not make any distinction between elective and emergency interventions and hence cannot be utilized to deny the petitioner the medical reimbursement to which he is legally entitled. In view of the principles laid down and observations made above, I hold that there is no justification in reimbursing the petitioner, the amounts that he had actually incurred for the treatment, less the deductible expenses. 16. In view of the discussion above, the petitioner is entitled to succeed. I hold that the petitioner is entitled to get medical reimbursement of the expenses incurred by him, as is evidenced by Exhibit P3, P6, P10, and P14. The WP(C) No. 32842 of 2022 16 respondents are directed to disburse the same after deducting the food expenditure from the bills within a period of 3 months from the date of receipt of a copy of this judgment. This writ petition will stand allowed. Sd/- **RAJA VIJAYARAGHAVAN V, JUDGE** NS WP(C) No. 32842 of 2022 17 ## **`APPENDIX OF WP(C) 32842/2022`** |`PETITIONER EXHIBITS`||| |---|---|---| |`Exhibit P1`|`TRUE`<br>`COPY`<br>`OF`<br>`THE`<br>`EMERGENCY`<br>`CERTIFICATE`<br>`DATED`|| ||`24/01/2022`<br>`ISSUED`<br>`FROM`<br>`ST.THOMAS`|`HOSPITAL,`| ||`CHETHIPUZHA TO THE PETITIONER`|| |`Exhibit P2`|`TRUE COPY OF THE DISCHARGE SUMMARY ISSUED FROM`|| ||`ST.THOMAS`<br>`HOSPITAL,`<br>`CHETHIPUZHA`|`TO`<br>`THE`| ||`PETITIONER`|| |`Exhibit P3`|`TRUE`<br>`COPY`<br>`OF`<br>`THE`<br>`INPATIENT`<br>`SERVICE `|`BILL WITH`| ||`ALL`<br>`BREAKUP`<br>`DETAILS`<br>`ISSUED`<br>`FROM`|`ST.THOMAS`| ||`HOSPITAL, CHETHIPUZHA TO THE PETITIONER`|| |`Exhibit P4`|`TRUE COPY OF THE COVERING LETTER WITH MEDICAL`|| ||`REIMBURSEMENT`<br>`CLAIM`<br>`FORM`<br>`DT:27.1.2022`|| ||`SUBMITTED`<br>`BY`<br>`THE`<br>`PETITIONER`<br>`TO`|`THE`<br>`4TH`| ||`RESPONDENT.`|| |`Exhibit P5`|`TRUE`<br>`COPY`<br>`OF`<br>`THE`<br>`EMERGENCY`<br>`CERTIFICATE`<br>`DATED`|| ||`12/02/2022`<br>`ISSUED`<br>`FROM`<br>`ST.THOMAS`|`HOSPITAL,`| ||`CHETHIPUZHA TO THE PETITIONER`|| |`Exhibit P6`|`TRUE COPY OF THE INPATIENT SERVICE BILL ISSUED`|| ||`FROM`<br>`ST.THOMAS`<br>`HOSPITAL,`<br>`CHETHIPUZHA`<br>`TO`<br>`THE`|| ||`PETITIONER`|| |`Exhibit P7`|`TRUE COPY OF THE DISCHARGE SUMMARY `|`ALONG WITH`| ||`ALL`<br>`DETAILS`<br>`ISSUED`<br>`FROM`<br>`ST.THOMAS`|`HOSPITAL,`| ||`CHETHIPUZHA TO THE PETITIONER`|| |`Exhibit P8`|`TRUE`<br>`COPY`<br>`OF`<br>`THE`<br>`COVERING`<br>`LETTER`<br>`DATED`|| ||`15.2.2022`<br>`WITH`<br>`MEDICAL`<br>`REIMBURSEMENT`<br>`CLAIM`|| ||`FORM`<br>`DATED`<br>`27.1.2022`<br>`SUBMITTED`|`BY`<br>`THE`| ||`PETITIONER TO THE 4TH RESPONDENT`|| |`Exhibit P9`|`TRUE`<br>`COPY`<br>`OF`<br>`EMERGENCY`<br>`CERTIFICATE`<br>`DATED`|| ||`16/03/2022`<br>`ISSUED`<br>`FROM`<br>`ST.THOMAS`|`HOSPITAL,`| ||`CHETHIPUZHA TO THE PETITIONER`|| |`Exhibit P10`|`TRUE COPY OF THE DISCHARGE BILL AND `|`CONNECTED`| ||`PAPERS`<br>`ISSUED`<br>`FROM`<br>`ST.THOMAS`|`HOSPITAL,`| ||`CHETHIPUZHA TO THE PETITIONER`|| |`Exhibit P11`|`TRUE`<br>`COPY`<br>`OF`<br>`THE`<br>`DISCHARGE`<br>`BILL`|`(SUMMARY)`| ||`DATED`<br>`04/03/2022`<br>`ISSUED`<br>`FROM`|`ST.THOMAS`| WP(C) No. 32842 of 2022 18 ``` HOSPITAL,CHETHIPUZHATOTHEPETITIONER ExhibitP12TRUECOPYOFTHECOVERINGLETTERDATED 1/04/2022WITHMEDICALREIMBURSEMENTCLAIM FORMDT.27.1.2022SUBMITTEDBYTHEPETITIONER TO4THRESPONDENT ExhibitP13TRUECOPYOFTHEEMERGENCYCERTIFICATEDATED 11/06/2022ISSUEDFROMST.THOMASHOSPITAL, CHETHIPUZHATOTHEPETITIONER ExhibitP14TRUECOPYOFTHEBILLALONGWITHALLDETAILS DATED11/06/2022ISSUEDFROMST.THOMAS HOSPITAL,CHETHIPUZHATOTHEPETITIONER ExhibitP15TRUECOPYOFTHECOVERINGLETTERDT:18.6.2022 WITHMEDICALREIMBURSEMENTCLAIMFORM DT.27.1.2022SUBMITTEDBYTHEPETITIONER BEFORE4THRESPONDENT ExhibitP16TRUECOPYOFTHELETTERDT:20.8.2022SUBMITTED BYTHEPETITIONERTOTHE4THRESPONDENT RESPONDENTANNEXURES AnnexureR3(a)THECALCULATIONSHEETINRESPECTOFTHECLAIM PREFERREDBYTHEPETITIONERFORTHEPERIODOF TREATMENTINBETWEEN10.01.2022TO17.01.2022 AnnexureR3(b)THECALCULATIONSHEETINRESPECTOFTHECLAIM PREFERREDBYTHEPETITIONERFORTHEPERIODOF TREATMENTINBETWEEN01.02.2022TO12.02.2022 AnnexureR3(c)THECALCULATIONSHEETINRESPECTOFTHECLAIM PREFERREDBYTHEPETITIONERFORTHEPERIODOF TREATMENTINBETWEEN22.02.2022TO04.03.2022 AnnexureR3(c)THECALCULATIONSHEETINRESPECTOFTHECLAIM PREFERREDBYTHEPETITIONERFORTHEPERIODOF TREATMENTINBETWEEN30.05.2022TO11.06.2022 ```