Facts of the Case
The petitioners were retired employees of various
nationalised banks who challenged the increase in health insurance premium
payable under the optional medical insurance scheme introduced pursuant to the
10th Bipartite Settlement. They contended that the premium charged to retired
employees was substantially higher than that charged to serving employees and
challenged the circulars issued by Canara Bank, UCO Bank and Punjab National
Bank revising the premium for the insurance period from 01.11.2019 to 31.10.2020.
The petitioners also sought directions requiring banks to bear the insurance premium from staff welfare funds and requested waiver of GST on health insurance premiums.
Issues Involved
- Whether retired bank employees are entitled to health insurance
premiums at the same rate as serving employees.
- Whether banks are legally bound to bear the insurance premium of
retired employees from staff welfare funds.
- Whether the Ministry of Finance letter and IBA Circulars create an
enforceable right in favour of retired employees.
- Whether charging higher insurance premiums from retired employees
violates Article 14 of the Constitution.
- Whether retired employees are entitled to waiver of GST on health insurance premiums.
Petitioners' Arguments
- The Ministry of Finance letter contemplated that banks should bear
the insurance premium through staff welfare funds instead of recovering
the amount from retired employees.
- At the inception of the insurance scheme, retired employees were
offered premiums comparable to serving employees and later arbitrary
increases defeated the legitimate expectation created by the scheme.
- Separate charges for domiciliary treatment were imposed only upon
retirees, resulting in discrimination.
- The IBA Circular stated that the Mediclaim Policy for retirees
would operate on similar terms and conditions as applicable to serving
employees; therefore, charging substantially higher premiums violated this
assurance.
- Serving employees enjoyed wider insurance coverage for dependents
while retired employees received comparatively limited benefits despite
paying higher premiums.
- Charging higher premiums from retirees amounted to discrimination and violated Article 14 of the Constitution.
Respondents' Arguments
- The impugned premium related only to the insurance year 2019–2020
and had already expired, rendering the challenge infructuous.
- The 10th Bipartite Settlement and the 2015 Joint Note clearly
provided that retired employees would be covered only upon payment of the
stipulated premium.
- The settlement expressly authorised individual banks to determine
the contribution payable by retired employees.
- The medical insurance scheme for retirees was optional and not
compulsory.
- The Ministry of Finance communication merely advised banks to
consider group insurance and did not mandate payment from staff welfare
funds.
- Neither the 10th Bipartite Settlement nor the 2015 Joint Note
guaranteed parity of premium between serving employees and retired
employees.
- Insurance companies revise premiums annually depending upon risk and actuarial considerations.
Court Order / Findings
The Delhi High Court dismissed all the writ
petitions.
The Court held that the challenge to the premium
applicable for the insurance period 2019–2020 had become infructuous since that
policy period had already expired.
The Court further held that the 10th Bipartite
Settlement and the 2015 Joint Note expressly required retired employees to pay
the stipulated premium and empowered individual banks to determine the
contribution payable by retirees.
The Ministry of Finance letter merely advised banks
that they may consider group insurance policies instead of direct
payment from staff welfare funds. The use of the word "may" made the
communication advisory rather than mandatory and created no enforceable legal
right.
Similarly, the IBA Circular regarding similar terms
and conditions was also advisory in nature and did not prohibit subsequent
revision of insurance premiums.
The Court observed that insurance policies are
renewed annually and insurers are free to revise premium rates in accordance
with law. Since retired employees ordinarily present a higher medical risk than
serving employees, charging higher premiums cannot be regarded as arbitrary or
discriminatory.
The Court also noted that the insurance scheme was
optional, and retired employees were free to opt for any other suitable medical
insurance policy if they considered the offered premium excessive.
The prayer seeking waiver of GST was rejected as no
statutory provision permitted such relief.
Accordingly, all writ petitions and pending applications were dismissed.
Important Clarification
- Retired bank employees do not possess a legal right to claim
insurance premiums equal to those charged to serving employees.
- The 10th Bipartite Settlement authorises banks to determine the
contribution payable by retired employees.
- The Ministry of Finance letter is advisory and not mandatory.
- The IBA Circular regarding similar terms and conditions does not
prevent future enhancement of insurance premiums.
- Higher insurance premiums for retired employees do not violate
Article 14 merely because retirees generally represent a higher medical
risk.
- Optional insurance schemes do not compel retirees to continue with
the bank-sponsored policy, and they remain free to obtain insurance from
alternative insurers.
- Waiver of GST cannot be granted in the absence of statutory
authority.
Sections Involved
- Article 14 of the Constitution of India
- Industrial Disputes Act, 1947
- Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970
- Officers' Service Regulations, 1979
- 10th Bipartite Settlement dated 25.05.2015
- Schedule IV of the 10th Bipartite Settlement
- 2015 Joint Note
- Ministry of Finance Letter dated 24.02.2012
- IBA Circular dated 01.10.2015
- Health Insurance / Medical Insurance Scheme for Bank Employees & Retirees
Link to
Download the Order
https://www.mytaxexpert.co.in/uploads/1785391648_2316compressed.pdf
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