Rita Chaurasiya and Another v. The State of Tamil Nadu and Others, 2026

The case concerned a mother seeking permission to donate one of her kidneys to her son who was suffering from systemic hypertension chronic kidney disease stage-V.

The son required an urgent kidney transplantation and was undergoing dialysis three times a week, causing severe physical pain and hardship.

The Authorisation Committee of the Directorate of Medical Education and Research refused to approve the kidney transplant on the ground that the relationship between the donor and recipient had not been satisfactorily established.

The petitioners challenged the rejection order before the Madras High Court, arguing that the decision was passed mechanically without proper appreciation of documents already submitted.

The mother contended that she had produced sufficient documents including the birth certificate, Aadhaar Card, and PAN Card establishing that the recipient was her biological son.

It was also argued that similarly placed persons had been granted approval and therefore the rejection was arbitrary and violative of Article 14 of the Constitution.

The petitioners further submitted that the order lacked proper reasoning and violated the principles of natural justice.

The Madras High Court held that a mother should not be compelled to undergo a DNA test to prove maternity when adequate documentary evidence establishes the biological relationship.

The Court observed that when the donor herself claimed that the recipient was her biological son, the request should not have been casually ignored by the authorities.

The Court examined the documents produced by the petitioners including the birth certificate, Aadhaar Card, and PAN Card.

The Court found that both the mother and son were linked through the name of Ratan Lal Chaurasia, thereby sufficiently proving the relationship.

Applying the principle of preponderance of probabilities, the Court concluded that the recipient was indeed the biological son of the donor.

The Court held that insisting upon a DNA test in such circumstances was unnecessary and unjustified.

The Court further observed that the authorities failed to provide adequate reasons while rejecting the request.

Considering the urgent medical condition of the son, the Court directed the Authorisation Committee to immediately permit the kidney donation and complete all necessary procedures without delay.

The judgment emphasizes a humanitarian and practical approach in medical authorization matters involving close family relationships.

The Court protected the dignity and privacy of individuals by refusing to mandate invasive DNA testing where documentary evidence was already sufficient.

By applying the principle of preponderance of probabilities, the Court reaffirmed that administrative decisions should be based on reasonable satisfaction rather than rigid technicalities.

The ruling reinforces the requirement that administrative authorities must provide proper reasoning and cannot reject applications mechanically.

The judgment also highlights the importance of timely judicial intervention in urgent medical cases involving life-saving treatment.

The decision strengthens constitutional protections under Article 14 by discouraging arbitrary and discriminatory administrative action.