Buerger’s Disease & Peripheral Vascular Disease Disability Pension in Armed Forces 2026

1. Why vascular disability-pension cases require careful classification

“Peripheral Vascular Disease” is often used as a broad expression. For pension purposes, however, the precise diagnosis matters. A case of chronic atherosclerotic Peripheral Arterial Occlusive Disease (PAOD) is not medically or legally identical to Buerger’s Disease (Thromboangiitis Obliterans), an acute arterial thrombosis in a high-altitude area, post-traumatic arterial ischaemia, vasculitis, Deep Vein Thrombosis (DVT), or Chronic Venous Insufficiency.

2. The most important 2025 authority: Ex Nk Amin Chand

In Union of India v. Ex Nk Amin Chand, decided by the Delhi High Court on 27 March 2025, the serviceman had been found suffering from Peripheral Arterial Occlusive Disease of the right lower limb. The Release Medical Board assessed the disability at 20% for life but treated it as neither attributable to nor aggravated by service.

The AFT granted disability pension, and the Delhi High Court declined to interfere. The important point was not that PAOD is automatically service-connected. Rather, the Court found the RMB’s reasoning inadequate: a bare conclusion that a disease arising during service is NANA, without a cogent explanation dissociating it from service, cannot by itself carry the denial.

3. Supreme Court: Ex Hav Mani Ram Bhaira — Bilateral PVD

The Supreme Court’s decision in Ex Hav Mani Ram Bhaira v. Union of India (11 February 2016) remains a major legacy authority. The appellant had entered service medically fit and was later discharged with Bilateral Peripheral Vascular Disease of the lower limbs assessed at 30% for life. The medical board declared the condition NANA.

The Supreme Court set aside the denial, applying the older entitlement-rule presumptions discussed in Rajbir Singh and related cases. It reiterated that where the member entered service fit and is later discharged with disability, the employer must support a conclusion of complete disconnection from service with reasons. The Court also granted the applicable rounding-off benefit.

Important: This judgment arose under the older legal framework. It should not be mechanically transplanted into a disability governed by the Entitlement Rules 2023 and GMO 2023.

4. GMO 2023 changes the analysis for PAOD and Buerger’s Disease

The Ministry of Defence promulgated the Entitlement Rules 2023 and Guide to Medical Officers 2023 on 21 September 2023. For disabilities reported or recorded after that date, the new framework must be examined first.

GMO 2023’s section on Peripheral Vascular Diseases states that chronic PAOD may present with intermittent claudication, rest pain, ischaemic ulcer or gangrene. It identifies smoking as a major risk factor and also refers to hypertension, diabetes, hyperlipidaemia, coronary artery disease and lack of exercise. It specifically notes Buerger’s Disease (Thromboangiitis Obliterans) as a disease seen in the younger male smoker involving small and medium vessels.

This makes the date of the medical board and exact vascular diagnosis critical. A 2008-rule PAOD claim and a post-21 September 2023 PAOD claim cannot safely be argued as if they were governed by the same medical guide.

5. Buerger’s Disease: tobacco history is central, but the diagnosis must still be proved

Buerger’s Disease is medically associated very strongly with tobacco exposure. Where the vascular surgeon or RMB has actually diagnosed Thromboangiitis Obliterans and documented a significant smoking/tobacco history, that record can materially affect entitlement. A claimant should therefore not assume that merely having been fit at enrolment will answer the modern GMO 2023 causation question.

At the same time, a pension authority should not casually label every lower-limb vascular disorder as “Buerger’s Disease” merely because there is a tobacco history. Important material may include angiography/CT angiography, Doppler findings, age at onset, distribution of arterial occlusion, diabetes status, lipid profile, evidence of atherosclerosis, vasculitis work-up and specialist vascular opinion.

6. High-altitude area: when limb ischaemia can become service-attributable

GMO 2023 separately recognises the hypercoagulable state associated with high-altitude exposure. Thus, an acute arterial thrombosis occurring during qualifying HAA tenure, or within the prescribed close temporal connection after de-induction, must be analysed differently from chronic atherosclerotic PAOD.

The evidence should establish:

• the exact HAA posting and dates;
• continuous qualifying tenure;
• date of first symptoms;
• arterial Doppler/angiography and hospital admission;
• whether the event was thrombosis, embolism or chronic occlusive disease;
• whether a service-related arterial injury preceded the ischaemia; and
• whether the medical board applied the specific HAA clause in GMO 2023.

7. When “peace station” is not enough

A frequent denial in older disability-pension cases is that the disease “arose in peace” or that the individual was not serving in field/HAA/CI operations when it manifested. The Delhi High Court in Amin Chand rejected a mechanical approach of that kind. The relevant question is whether the applicable rules and medical evidence justify the conclusion that service neither caused nor aggravated the disability.

For post-2023 PAOD, however, the analysis is different because GMO 2023 itself contains a condition-specific medical rule. A claimant cannot rely only on the weakness of a “peace area” sentence if the substantive modern guide independently classifies the disease as non-attributable. The challenge must then focus on correct diagnosis, correct rule, recognised exceptions, service injury/HAA nexus, and the factual accuracy of the medical reasoning.

8. Percentage assessment: symptoms matter

The percentage is a separate question from attributability. Vascular impairment may depend on the severity and persistence of functional loss, including:

• distance walked before claudication;
• rest pain;
• loss of pulses and objectively documented arterial flow reduction;
• ischaemic ulceration;
• gangrene;
• sympathectomy or vascular intervention;
• toe/foot/below-knee/above-knee amputation;
• prosthesis and mobility restrictions; and
• recurrence/progression despite treatment.

In Mani Ram Bhaira, Bilateral PVD had been assessed at 30% for life. In Amin Chand, PAOD was assessed at 20% for life. These percentages are case-specific and should not be treated as fixed percentages for every PVD diagnosis.

9. Amputation does not automatically decide attributability

An amputation may dramatically increase functional disability, but it does not by itself answer whether the underlying vascular disease was attributable to or aggravated by service. The enquiry should separately address:

1. What caused the arterial occlusion?
2. Was that cause service-attributable under the applicable rules?
3. Was the amputation a direct consequence of that disease/injury?
4. What is the correct post-amputation percentage?
5. Is the disability permanent or subject to reassessment?

An older Delhi High Court decision, Ex S/K Kanhaiya Lal v. Union of India, dealt with Peripheral Vascular Disease followed by below-knee amputation and rejected the attempt to deny pension merely by asserting that the vascular disease had no service connection without adequate foundation.

10. Broad-banding / rounding off

Where a claimant is otherwise legally entitled to disability element and the applicable broad-banding rules are satisfied, the percentage may be rounded according to the governing policy. The current DESW broad-banding framework generally operates through the familiar slabs of up to 50% → 50%, above 50% to 75% → 75%, and above 75% to 100% → 100%, subject to the applicable category and conditions.

For a detailed explanation, see our guide on broad-banding and the Supreme Court’s Girish Kumar ruling. Broad-banding should be pleaded as a separate consequential issue after entitlement is established.

11. Documents that matter in a PVD / Buerger’s Disease case

12. Common vulnerable NANA findings

13. Potential AFT grounds

Depending on the rule set and record, grounds may include:

• failure to apply the correct Entitlement Rules/GMO applicable to the date of disability;
• non-speaking or cryptic NANA opinion in a legacy-rule claim;
• failure to identify the actual cause despite fit enrolment and long service;
• misdiagnosing PAOD as Buerger’s Disease or vice versa;
• ignoring qualifying HAA arterial thrombosis;
• ignoring a service-related arterial injury;
• inconsistency between specialist opinion, category board and RMB;
• incorrect percentage assessment after ulceration, gangrene or amputation;
• failure to grant broad-banding after entitlement is established; and
• unreasoned rejection of statutory appeals.

For the broader NANA framework, see Attributable or Aggravated by Military Service? NANA Medical Board & AFT Challenge. For the overall pension framework, see our Armed Forces Disability Pension guide.

14. Related vascular and metabolic conditions

A PVD claim may overlap with other conditions. Where relevant, the service record should be read together with:

• Type-II Diabetes Mellitus disability pension;
• Primary Hypertension disability pension;
• Coronary Artery Disease / IHD disability pension; and
• Varicose Veins / Chronic Venous Insufficiency disability pension.

15. Frequently Asked Questions

Is Buerger’s Disease automatically NANA?

No single answer is safe without identifying the applicable rules and the actual medical record. Under GMO 2023, Buerger’s is specifically discussed in the PAOD section in association with younger male smokers, and PAOD per se is stated to be non-attributable. Legacy cases require analysis under the older rule set and controlling precedent.

Can smoking history defeat a disability-pension claim?

It can be highly relevant where a competent medical board/specialist establishes that tobacco exposure is causally linked to the diagnosed condition. But the authority should rely on the actual record rather than inventing a risk factor later in litigation.

Does high-altitude service matter?

Yes, particularly for acute arterial thrombosis/limb ischaemia occurring during qualifying HAA tenure or in the close post-deinduction window recognised by GMO 2023.

Can 20% PVD be rounded to 50%?

If disability-pension entitlement is established and the claimant falls within the applicable broad-banding policy, rounding may be available. Amin Chand involved 20% PAOD and the AFT relief was upheld.

What if the RMB only writes “NANA — peace station”?

For a legacy claim, that may be vulnerable if the applicable rules require a reasoned medical explanation. For a post-2023 claim, the condition-specific GMO rule must also be addressed; a defective sentence does not automatically override an express modern rule.