Landmark Judgments On Right To Life And Personal Liberty
Right to Life and Personal Liberty: Constitutional Basis
Article 21 of the Indian Constitution guarantees that “No person shall be deprived of his life or personal liberty except according to procedure established by law.”
Over time, the Supreme Court has expansively interpreted this right to include a wide range of protections beyond mere survival, making it a cornerstone of Indian constitutional law.
Landmark Judgments on Right to Life and Personal Liberty
1. Maneka Gandhi vs. Union of India (1978) 1 SCC 248
Facts:
Maneka Gandhi’s passport was impounded without a proper hearing, violating her right to travel abroad.
Key Points:
The Supreme Court held that “procedure established by law” must be “just, fair and reasonable” and not arbitrary or oppressive.
Expanded the scope of Article 21 by linking it with Articles 14 (Equality) and 19 (Freedom).
Introduced the doctrine of due process, rejecting the earlier narrow view.
Importance:
This case revolutionized the interpretation of Article 21 by ensuring that any law depriving personal liberty must follow a fair procedure, making the right to life and liberty a substantive right.
2. Kharak Singh vs. State of UP (1962) 1 SCR 332
Facts:
The case challenged police surveillance and domiciliary visits as violating personal liberty.
Key Points:
The Supreme Court recognized that personal liberty under Article 21 includes the right to privacy, even though it was not explicitly mentioned in the Constitution then.
However, it allowed domiciliary visits under certain restrictions, emphasizing the need to balance security and liberty.
Importance:
One of the earliest cases recognizing privacy as part of personal liberty and setting limits on state intrusion.
3. Gian Kaur vs. State of Punjab (1996) 2 SCC 648
Facts:
The petitioner challenged the constitutionality of laws criminalizing euthanasia and abetment to suicide.
Key Points:
The Court held that the right to life does not include the right to die.
Suicide attempts remain punishable under Section 309 of the IPC.
The judgment distinguished “right to life” from “right to die with dignity.”
Importance:
Clarified limits of Article 21, reaffirming the sanctity of life, though later developments modified this position (e.g., passive euthanasia allowed under strict conditions).
4. Justice K.S. Puttaswamy (Retd.) vs. Union of India (2017) 10 SCC 1
Facts:
Challenged the government’s Aadhaar scheme on grounds of violating the right to privacy.
Key Points:
The Supreme Court unanimously declared right to privacy as a fundamental right protected under Article 21.
Privacy includes protection of personal data, bodily autonomy, and informational privacy.
The ruling imposed restrictions on government surveillance and data collection.
Importance:
A watershed judgment affirming privacy as an intrinsic part of life and liberty in the digital age.
5. Olga Tellis vs. Bombay Municipal Corporation (1985) 3 SCC 545
Facts:
Slum dwellers challenged eviction orders, claiming eviction violated their right to livelihood.
Key Points:
The Court held that right to life includes the right to livelihood.
Eviction without alternative accommodation violates Article 21.
Life means more than mere animal existence; it includes dignified living.
Importance:
Expanded Article 21 to cover economic rights and dignity, balancing state power and social justice.
Summary
Article 21 is a dynamic and expansive right protecting not just physical survival but also dignity, privacy, and livelihood.
The judiciary has broadened its scope through progressive and protective interpretations.
Cases like Maneka Gandhi ensured fair procedure; Puttaswamy affirmed privacy; Olga Tellis included livelihood.
These judgments protect citizens from arbitrary state action and affirm human dignity as fundamental to life.
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