S. Rajaseekaran v. Union of India & Ors

On January 8, 2025, the Supreme Court of India delivered a landmark judgment in the case of S. Rajaseekaran v. Union of India & Ors., emphasizing the critical need for immediate medical attention to motor accident victims during the "golden hour"—the first hour following a traumatic injury, which is crucial for preventing fatalities. The Court directed the Central Government to formulate and implement a comprehensive scheme ensuring cashless treatment for such victims by March 14, 2025.

Background
The Motor Vehicles Act, 1988, was amended to include Section 162, which mandates the Central Government to establish a scheme for the cashless treatment of road accident victims during the golden hour. Despite this provision coming into effect on April 1, 2022, the absence of an operational scheme prompted judicial intervention. The petitioner, Dr. S. Rajaseekaran, highlighted the alarming number of fatalities resulting from delayed medical care due to procedural and financial barriers.

Court's Observations
The Supreme Court underscored that the provision of immediate medical treatment during the golden hour is integral to the right to life guaranteed under Article 21 of the Constitution. The Court noted that delays often occur because hospital authorities await police procedures or are concerned about payment assurances, leading to critical loss of time. The bench, comprising Justice Abhay S. Oka and Justice Augustine George Masih, emphasized that the statutory obligation under Section 162 seeks to uphold and protect this fundamental right.

Directives Issued
The Court directed the Central Government to:

1. Formulate the Scheme: Develop a comprehensive scheme for cashless treatment during the golden hour by March 14, 2025.
2. Address Concerns: Ensure that the scheme does not impose restrictive conditions, such as a maximum treatment cap of ₹1,50,000 or a treatment duration limit of seven days, which could undermine its effectiveness.
3. Submit Implementation Plan: File an affidavit by March 21, 2025, detailing the implementation strategy of the scheme.

Additionally, the General Insurance Council (GIC) was instructed to expedite the development of a digital portal to streamline the processing of compensation claims, particularly for hit-and-run cases, and to address any pending claims by coordinating with the claimants to rectify documentation deficiencies.

Legal and Policy Implications
This judgment reinforces the constitutional mandate to preserve life through timely medical intervention. By holding the Central Government accountable for implementing the statutory provisions of the Motor Vehicles Act, the Court has taken a significant step toward reducing fatalities resulting from road accidents. The directive to establish a cashless treatment scheme aims to eliminate financial and procedural barriers that hinder immediate medical care, thereby potentially saving numerous lives.

Conclusion
The Supreme Court's decision in S. Rajaseekaran v. Union of India & Ors. serves as a pivotal moment in India's road safety jurisprudence. By mandating the implementation of a cashless treatment scheme during the golden hour, the Court has prioritized the sanctity of human life over procedural formalities and financial constraints. This judgment not only upholds the fundamental right to life but also sets a precedent for proactive judicial intervention in enforcing legislative mandates aimed at public welfare.

In essence, the ruling underscores the principle that timely medical care should be accessible to all, regardless of financial standing, especially in life-threatening situations arising from road accidents. The effective implementation of this scheme will require concerted efforts from the government, healthcare institutions, and insurance bodies to create an ecosystem where the value of human life is paramount.