On 19 April 2021, Justice Pratibha M. Singh of the Delhi High Court held that Section 21(4) of the Mental Healthcare Act 2017 imposes a positive, justiciable statutory obligation on every insurer to provide mental-illness cover on the same basis as physical illness, and that any policy clause excluding or sub-limiting mental-illness cover is void to the extent of inconsistency with the Act. The judgment directed National Insurance to reimburse the petitioner's Rs.5.54 lakh schizoaffective-disorder claim and required the IRDAI to circulate the order to every insurer. It was the doctrinal foundation for the IRDAI's 18 October 2022 circular and for the 2024 Master Circular on Health Insurance Business.