The Kerala High Court dismissed a challenge by a father who was denied Rs 6,000 in Pradhan Mantri Matru Vandana Yojana benefits because he had not vaccinated his second girl child, a mandatory scheme condition. The court held that conditioning maternity benefits on vaccination does not violate fundamental rights and serves a legitimate public health objective. The ruling affirms that welfare scheme conditions tied to child healthcare are constitutionally permissible under Articles 14 and 21.

The PMMVY (Pradhan Mantri Matru Vandana Yojana), launched in 2017 under the PMMVY Act and governed by the Ministry of Women and Child Development, provides partial wage compensation of Rs 6,000 to pregnant and lactating mothers. The scheme disburses the benefit in instalments linked to conditions including registration of pregnancy and vaccination of the child.

The constitutional challenge here rested on Articles 14 (equality), 19, and 21 (right to life and personal liberty). The petitioner argued that denying benefits for failure to vaccinate amounted to coercive state action against a fundamental right.

The Kerala HC applied the reasonable classification test under Article 14 and the proportionality test under Article 21. The court found: (1) the classification — linking cash benefits to a child health action — has an intelligible differentia with a rational nexus to the scheme's object; (2) the condition is not punitive but incentive-based; (3) the State has a compelling interest in maternal and child health under the Directive Principles (Articles 39(e), 47).

The ruling distinguishes compulsory vaccination (which may attract bodily autonomy challenges under Art 21) from conditional benefits (where the State merely declines to extend a gratuitous welfare payment unless a public-health step is taken). This distinction — coercion vs. conditional entitlement — is the core doctrinal takeaway for CLAT PG applicants.