Roadmap for Answer Writing
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Introduction (30-40 words)
- Briefly introduce Article 21 of the Indian Constitution.
- State the significance of judicial interpretation in expanding the scope of this fundamental right.
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Historical Background (50-60 words)
- Mention the initial interpretation of Article 21, which was limited to protecting physical existence.
- Acknowledge how the courts have progressively expanded its meaning to include a range of rights integral to human dignity and liberty.
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Key Judicial Developments (160-180 words)
- Discuss landmark case laws that have broadened the scope of Article 21, providing detailed facts and judicial reasoning behind each decision. You can divide this into subheadings for each case law.
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Conclusion (30-40 words)
- Summarize how these evolving interpretations reflect the Court’s commitment to safeguarding human dignity.
- Conclude by emphasizing the transformative impact on individual rights and the protection of personal liberty.
Relevant Facts and Case Laws
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Olga Tellis & Ors. vs. Bombay Municipal Corporation (1986)
Fact: The Supreme Court held that the right to life under Article 21 includes the right to livelihood. The Court stated that no one can live without means of subsistence.
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Pt. Parmanand Katara vs. Union of India (1989)
Fact: The Court emphasized the State’s duty to ensure urgent medical assistance, declaring that every medical professional is obligated to provide emergency medical care, thus extending the right to life to include medical aid.
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Subhash Kumar vs. State of Bihar (1991)
Fact: The Court expanded Article 21 to include the right to a healthy environment, ruling that every person has the right to live in a pollution-free environment, encompassing the right to clean air and water.
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Justice K.S. Puttaswamy (Retd.) vs. Union of India (2017)
Fact: The Court declared that the right to privacy is a fundamental right under Article 21, intrinsic to the right to life and personal liberty. This decision reflected the growing importance of personal autonomy in the context of digital privacy.
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Common Cause vs. Union of India (2018)
Fact: The Court recognized the right to die with dignity, permitting passive euthanasia under strict guidelines, and ruled that the right to life includes the right to die with dignity.
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M K Ranjitsinh & Ors. vs. Union of India (2024)
Fact: The Court ruled that the right to be free from the adverse effects of climate change is included under the scope of Article 21, recognizing the environmental aspects as integral to the right to life and personal liberty.
Model Answer
Article 21 of the Indian Constitution guarantees the right to life and personal liberty. Over time, the Supreme Court of India has expanded the scope of this fundamental right, interpreting it beyond mere physical existence to encompass a wide range of human needs and dignity.
Right to Livelihood: Olga Tellis (1986)
In Olga Tellis & Ors. vs. Bombay Municipal Corporation (1986), the Supreme Court interpreted the right to life to include the right to livelihood. The Court held that no one can live without the means of subsistence, thereby extending the scope of Article 21 to encompass the right to earn a living as a fundamental component of life.
Right to Medical Assistance: Pt. Parmanand Katara (1989)
In Pt. Parmanand Katara vs. Union of India (1989), the Court ruled that medical professionals are obligated to provide urgent medical care to all individuals, regardless of their background or financial status. This decision expanded Article 21 to include the right to immediate medical treatment, reflecting the right to life as encompassing health care.
Right to a Healthy Environment: Subhash Kumar (1991)
The Subhash Kumar vs. State of Bihar (1991) judgment further extended Article 21, declaring that the right to life includes the right to live in a pollution-free environment. This ruling emphasized the State’s responsibility to ensure access to clean air and water, which are essential for survival and well-being.
Right to Privacy: Justice K.S. Puttaswamy (2017)
The Justice K.S. Puttaswamy (Retd.) vs. Union of India (2017) case marked a landmark judgment in which the Supreme Court affirmed that the right to privacy is intrinsic to the right to life and personal liberty under Article 21. The Court held that privacy is an essential aspect of human dignity, thus expanding the interpretation of personal liberty.
Right to Die with Dignity: Common Cause (2018)
In Common Cause vs. Union of India (2018), the Court recognized the right to die with dignity, allowing passive euthanasia. This ruling acknowledged that the right to life also includes the right to choose the manner and timing of one’s death, further broadening the scope of personal liberty.
Right to Protection from Climate Change: MK Ranjitsinh (2024)
The Supreme Court, in M K Ranjitsinh & Ors. vs. Union of India (2024), recognized the right to be free from the harmful effects of climate change as part of the fundamental right to life under Article 21. This ruling reflects the Court’s recognition of environmental factors as critical to the protection of human life and dignity.
Through these evolving interpretations, the scope of Article 21 has significantly expanded, ensuring a broader, more inclusive protection of fundamental rights in India.