Pension Benefit to Stepmother

Source: Supreme Court  

Why in News? 

Recently, Justices Surya Kant, Ujjal Bhuyan and N Kotiswar Singh held that for welfare legislations like pension schemes, the term “mother” should be interpreted purposively to include a stepmother who has fulfilled the role of a mother and not be confined only to the biological mother. 

• The Supreme Court held this in the matter of Jayashree Y Jogi v. Union of India and Ors (2025). 

What was the Background of Jayashree Y Jogi v. Union of India and Ors (2025) Case? 

• The case involves a stepmother seeking pension benefits following the death of her stepson who served as an Airman in the Indian Air Force. When the deceased officer was six years old, his biological mother passed away. Subsequently, his father remarried, and the appellant (stepmother) took responsibility for raising the child from that tender age. 
• The stepson grew up under the care and custody of his stepmother and eventually joined the Indian Air Force, serving as an Airman at an Air Force Camp. Tragically, on 30th April 2008, the officer died due to aluminium phosphide poisoning, which was classified as suicide following an internal enquiry conducted by the authorities. 
• In 2010, the stepmother approached the Air Force Record Office seeking Special Family Pension as the deceased officer's mother. Her application was rejected on the grounds that she was not the biological mother of the deceased.  
• Additionally, her claim for Ordinary Family Pension was also denied due to income criteria, as the combined annual income of the parents (approximately Rs. 84,000) exceeded the prescribed limit of Rs. 30,000 as stipulated in a Ministry of Defence communication dated 1998. 
• Aggrieved by the administrative rejection, the appellant approached the Armed Forces Tribunal, Kochi, challenging the denial of pension benefits. The Tribunal upheld the administrative decision, observing that a stepmother cannot be considered equivalent to a mother for the purpose of granting special family pension under the existing regulations. The Tribunal also rejected her claim for ordinary family pension, citing the income threshold criteria as the determining factor. 
• Following the adverse decision of the Armed Forces Tribunal, the appellant approached the Supreme Court of India, challenging the restrictive interpretation of the term "mother" in pension regulations and seeking recognition of her role as the primary caregiver who raised the deceased officer from childhood. 

What were the Court’s Observations? 

• The Supreme Court expressed the view that for welfare purposes, particularly in pension schemes, the expression "mother" should not be interpreted as a static or rigid term.  
• The Court Observed that each case should be examined based on its particular facts to determine who performed the maternal role in a child's life, rather than limiting benefits exclusively to biological mothers. 
• Justice Kant posed hypothetical situations to the Indian Air Force counsel to highlight the potential injustice of rigid interpretation. 
• The Court questioned what would occur in circumstances where a biological mother abandons her child and the father or grandmother assumes caregiving responsibilities, only for the biological mother to return after decades claiming entitlement.  
• Conversely, the Court examined scenarios where a biological mother dies during childbirth complications, and a stepmother assumes full responsibility for raising the child. 
• The Court suggested that the definition of "mother" could be interpreted flexibly based on factual circumstances to determine who genuinely fulfilled the maternal role. The bench questioned why the term "mother" should remain static and why adoptive parents should be excluded from pension benefits when they have performed parental duties. 
• When the Indian Air Force counsel argued that existing Supreme Court precedents limited the term "mother" to biological mothers only, and that regulations under the Pension Regulations for the Air Force 1961 were clear and unchallenged, the Court distinguished such precedents. Justice Kant noted that pension regulations are not constitutional mandates but administrative decisions, questioning the underlying logic for depriving stepmothers of pension benefits. 
• The Court observed that pension legislation should be interpreted with a purposive and social approach rather than a restrictive technical interpretation. The bench noted that existing regulations define a "motherless child" as one not in the custody of either a mother or stepmother, suggesting that the term "mother" should encompass stepmothers within the regulatory framework. 
• The Court impressed upon the Indian Air Force the necessity for flexibility in provisions to accommodate case-by-case determination rather than applying blanket exclusions. The bench emphasized that welfare schemes should consider the substantive relationship and caregiving role rather than merely biological connections. 
• The Court directed counsel to examine comparative statutes, rules, and regulations containing similar definitions, analysing how courts have expanded their interpretation, the rationale behind such expansion, and the liberal approach adopted in social and welfare legislation cases. 

What are Legal Points Established? 

• Statutory Interpretation - Meaning of "Mother" in Welfare Legislation 
  • Primary Issue: Whether the term "mother" in pension regulations should be interpreted restrictively to include only biological mothers or expansively to include those who functionally performed maternal roles. 
  • Legal Principle: The case raises fundamental questions about statutory interpretation, particularly whether welfare legislation should be interpreted liberally to achieve its purpose or strictly according to literal meaning. 
• Constitutional Law - Right to Equality and Non-Discrimination 
  • Equal Treatment Principle: The case involves potential violation of Article 14 (Right to Equality) of the Indian Constitution by creating artificial distinctions between biological and non-biological mothers who have performed identical caregiving functions. 
  • Substantive v. Formal Equality: The legal question centres on whether equality means treating all similarly situated persons identically (formal equality) or recognizing functional equivalence in relationships (substantive equality). 
• Administrative Law - Reasonableness of Classification 
  • Reasonable Classification Test: The case examines whether the administrative distinction between biological mothers and stepmothers in pension regulations constitutes a reasonable classification based on intelligible differentia having rational nexus to the object sought to be achieved. 
  • Arbitrary State Action: The challenge questions whether denying pension benefits to stepmothers who raised deceased officers constitutes arbitrary administrative action lacking rational basis. 
• Family Law - Legal Recognition of Step-Relationships 
  • De Facto v. De Jure Parentage: The case explores the legal recognition of functional parent-child relationships that exist in fact (de facto) versus those recognized by law (de jure). 
  • Parental Rights and Responsibilities: Legal examination of whether assumption of parental responsibilities should confer corresponding parental rights, including succession and benefit entitlements. 
• Precedential Law - Distinguishing Previous Judgments 
  • Application: The case involves distinguishing between different legal contexts where the term "mother" has been interpreted, such as maintenance under Section 125 CrPC versus pension benefits under service regulations. 
  • Evolving Jurisprudence: Recognition that legal definitions may require evolution to address changing social realities and family structures.