Beneficial Scheme Cannot Be Defeated by Retrospective Limitation: Punjab & Haryana HC Grants Relief Under Deen Dayal Yojna
Case Name: Sarla v. State of Haryana & Others
Date of Judgment: 27.03.2026
Citation: CWP-9253-2026
Bench: Hon’ble Mr. Justice Jagmohan Bansal
Held: The High Court held that a limitation period introduced subsequently in a beneficial welfare scheme cannot be applied retrospectively to defeat an accrued right. Beneficial schemes must be interpreted liberally in favour of claimants.
Summary: The petitioner approached the High Court challenging the rejection of her claim for compensation under the Deen Dayal Upadhyaya Antyodaya Parivar Suraksha Yojna on the ground of delay.
Her husband had died on 30.09.2023, and she applied for compensation on 03.02.2024. The claim was rejected on the basis that it was filed beyond 90 days from the date of death.
The petitioner contended that when the scheme was introduced on 24.05.2023, no limitation period was prescribed. The 90-day limitation was introduced later through a notification dated 09.11.2023. She argued that her application was within 90 days from the date of the amendment and thus could not be treated as time-barred.
The State argued that the limitation should apply retrospectively from the date of death.
The Court observed that the scheme in question is a beneficial welfare scheme and must be interpreted liberally. It further held that although procedural amendments are generally retrospective, any amendment affecting vested rights cannot operate retrospectively unless explicitly stated.
In the present case, the amendment introducing limitation did not specify retrospective application. Therefore, the petitioner’s right to claim compensation, which had already accrued, could not be defeated by applying the limitation retrospectively.
The Court also took note of the State’s submission that the Government was itself considering extending the limitation period from 90 days to six months.
Decision: The High Court allowed the writ petition and directed the respondents to release compensation to the petitioner under the scheme within two months.