1/18/23, 1:17 PM Right to life - iPleaders

Right to life
By Rachit Garg - June 10, 2022

This article is written by Neha Dahiya, a law student at Dr. B.R. Ambedkar National Law
University. This article explains the origin of right to life and also elaborates on Article 21
including its various elements and broad interpretations given in several judicial decisions.
It also contains the provisions for right to life in countries other than India. 

It has been published by Rachit Garg.

Table of Contents 

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1. Introduction 
2. History of right to life 
3. Article 21 of the Indian Constitution 
3.1. Meaning and concept of right to life 
3.2. Meaning and concept of personal liberty
3.3. Meaning and concept of personal dignity
3.4. Procedure established by law 
4. Scope of Article 21 of the Indian Constitution
5. Elements of Article 21 of the Indian Constitution
5.1. Right to health and medical care
5.2. Right to shelter 
5.3. Right to clean and healthy environment 
5.4. Right to freedom from noise pollution 
5.5. Right to privacy 
5.6. Rights to education
5.7. Right to information 
5.8. Right to a speedy trial 
5.9. Right to livelihood 
5.10. Right to die 
5.11. Right to travel abroad
5.12. Right to free legal aid 
5.13. Right against handcuffing 
5.14. Right against inhuman treatment 
5.15. Right against sexual harassment 
5.16. Right to sleep 
5.17. Right against solitary confinement 
5.18. Right to reputation 
5.19. Right against public hanging 
5.20. Right to water and electricity 
5.21. Rights of prisoners to have necessities of life
5.21.1. Right against custodial harassment 
6. What is Article 21A of the Indian Constitution
7. Right to life in conflict with death penalty 
8. Is right to life an absolute right
9. Right to life in other countries 
9.1. The United States of America
9.2. The United Kingdom 
10. Conclusion 
11. FAQs
11.1. What is Article 21?
11.2. Is the right to life an absolute right?
11.3. Does the right to life include the right to die?
11.4. What is the difference between the ‘due process of law’ and the ‘procedure established by
the law’?
12. References 

Introduction 
“To deny people their human rights is to challenge their very humanity” – Nelson Mandela

Human rights have formed the foundation of civilised human life from the beginning. They
are sacred, inviolable, universal, and inalienable. They protect the sanctity of human life.
One of the most essential of these rights is the right to life. The right to life guarantees that

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no person can be deprived of his life and personal liberty, except in accordance with the
procedures established by the law. Article 21 of the Indian Constitution guarantees the right
to life and personal liberty. It has three important elements, which are life, liberty, and
dignity. Over time, due to growing judicial activism and the concern for human rights, the
scope of Article 21 has been expanded to include a variety of other elements as well that
make human life fulfilling and worth living. 

History of right to life 

The history of the right to life overlaps with the history of the development of human rights.

The first formal codification of human rights can be found in the tablet of Hammurabi. It
was built 4000 years ago by Sumerian King Hammurabi and was a legally binding document
that protected people from unjust and arbitrary harassment and punishment. In Greece,
‘human rights’ became synonymous with ‘natural rights’ with the emergence of the natural
school of law. Greek thinkers like Socrates and Plato believed that nature was the
embodiment of the will of Gods who controlled the law.  A new concept of human rights
took birth with the idea of positive law, which subjected human rights to a positivist
approach, i.e., under the control of the sovereign will. The concepts of life and individual
liberty can also be found in ancient Indian literature like the Rig Veda and the
Mahabharata. 

It was during the British era that a formal demand for fundamental rights was made. The
British made laws that suited them and were favorable for them, completely disregarding
the rights of Indian citizens. Various laws were brought that unjustly took away the right to
life and personal liberty of the Indians, just to suppress anti-British activities and
sentiments. Thus, a demand for a Fundamental Rights Bill was made between 1917 and
1919, and several resolutions were passed to this effect by the Indian National Congress.
The Nehru Report of 1928 concluded that “No one shall be deprived of his liberty,
sequestered or confiscated, save in accordance with the law.”

Finally, with the coming of the Indian Constitution in 1950, all Indian citizens were granted
certain fundamental rights, including the right to life and personal liberty. 

Article 21 of the Indian Constitution 

Article 21 of the Indian Constitution covers the arena of protection of human life and liberty.
It prescribes that “no person shall be deprived of his life or personal liberty except
according to the procedure established by law.” 

Article 21 guarantees the right to life and personal liberty to every person, which cannot be
violated even by the state, except when stipulated by the law to prevent encroachment on
and the loss of life. Thus, it has been rightly called the “procedural Magna Carta protective
of life and liberty” by Justice Iyer. The most striking feature of this Article is that it provides
the right to life to not only the citizens of our country but also to the foreigners. Thus, even
a foreigner can seek protection from Article 21 in India. However, Article 21 can be enforced

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only against the state and not against private individuals. Any person whose right under
Article 21 has been violated can approach the honourable Supreme Court under Article 32
or any High Court under Article 226. 

Meaning and concept of right to life 

The right to life, liberty, and security of a person has been covered under Article 3 of the
Universal Declaration of Human Rights. Additionally, Article 6 of the International Covenant
on Civil and Political Rights provides that “every human being has the inherent right to life.
This right ought to be protected by the law and no one shall be deprived of his life
arbitrarily.” Right to life can also be found embedded in the constitutions of different
countries around the world.

Thus, the right to life is the most basic of all other rights. Fundamentally, this right seeks to
protect the unjust deprivation of human life by the state. It prescribes that no one can be
deprived of his/her life, except as per the law. 

In India, the right to life has been granted a very broad connotation. As per Article 21 and
its judicial interpretations, ‘life’ is not simply just the physical act of breathing. It extends
beyond mere animal existence and includes a canopy of other elements as well. It includes
the right to live with dignity, right to health, right to livelihood, right to privacy, and a
bundle of other similar rights. It is, without a doubt, the most significant of all other
fundamental rights. It forms the support system for all other rights, being the primary of
them all. 

As humans, the right to life forms the essence of our very existence. This is because we
cannot survive as humans fully without having access to all other allied elements like
health, liberty, safety, etc. to make our life worth living and complete. Thus, it includes the
minimum necessities that must be made available to every human being so that he/she is
able to live to the fullest and take maximum advantage of this life. 

Meaning and concept of personal liberty

The mention of personal liberty formally dates back to 1215 when the English Magna Carta
stated that ‘No freeman shall be taken or imprisoned, except by the law of the land’.
Personal liberty, as defined by Black’s Law Dictionary, is ‘the right of freedom of a person to
behave as they would like. Though following the code of conduct of the society in which a
person resides is important’. Personal liberty forms an essential part of life, as per Justice
Field in the American case of Munn v. Illinois (1877). It implies that all men are born free
and must remain the same way. However, in order to live peacefully together in a society,
liberty cannot be allowed to transform into license. Thus, some reasonable restrictions are
placed on it. That is why personal liberty implies no one can be wrongfully restrained,
except when it is required by the law.

In India, the concept of personal liberty came into the limelight with the case of A.K.
Gopalan v. State of Madras (1959). The case was about the detention of a communist

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leader who claimed that the detention was illegal and breached his personal liberty under
Article 21. The Court described the ambit of personal liberty as including the liberty of the
physical body, and even the right to sleep, eat, etc. Again in Kharak Singh v. State of U.P.
and Others (1964), it was outlined that personal liberty not only contained the right to be
free from restrictions on one’s movements but also from restrictions placed on our private
life. 

Meaning and concept of personal dignity

The concept of dignity started with the idea of dignitas hominis in classical Roman thought
and it translated to mean ‘status’. Honor and respect were given to the person worthy of it
because of attaining a particular status. Thus, the worthiness of a person and his charisma
were measured by his status which accorded him his dignity. In a border sense, some of the
Roman writings, like Cicero’s, also mention dignity to be attached to a human being per se,
without any references to his status. It was believed that humans have been endowed with
superior faculties to the rest of the creatures, like the faculty to reason. Later on, with
various movements and revolutions going on around the world, dignity came to be attached
to material conditions of human beings like food, clothing, shelter, and other basic facilities
that ought to be delivered to every human as a part of his dignity to live like a human. 

In modern times, dignity is also closely related to abstract concepts like class, caste,
religion, race, and gender divisions. Various factors like education, health, employment,
freedom from hunger, social security, and social, economic, and political rights ensure a
dignified life for a human. Now, these factors may vary depending upon the above-
mentioned abstract concepts. Article 21 ensures that everyone gets equal access to these
factors. 

It was also held in the case of Francis Coralie Mullin v. Administrator, Union Territory of
Delhi (1981), that “Right to life enshrined in Article 21 cannot be restricted to mere animal
existence and goes beyond just physical survival. Right to life includes the right to live with
dignity and all that goes along with it, namely the bare necessities of life like adequate
nutrition, clothing and shelter, facilities for reading, writing, and expressing oneself in
diverse forms, and freely moving and mixing with fellow humans.” 

Procedure established by law 

Article 21 stipulates that the right to life and personal liberty can be taken away by the
procedure established by the law. The procedure established by law is a technical term that
implies the procedure prescribed by any statute or the law of the state. It was extensively
dealt with in the case of A.K. Gopalan v. State of Madras (1959), where the validity of the
Preventive Detention Act, 1950 was challenged. 

The Court observed that ‘procedure established by law’, as mentioned in Article 21 refers to
nothing but the law enacted by the Indian legislature. Thus, if a law is laid down by our
Parliament that deprives someone of his life or liberty would be valid. Here, under this

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principle, the reasonableness or the validity of the law establishing the procedure itself was
not the concern. The only essential requirements were:

1. There must be a law established by the legislature validly;

2. The law must lay down a procedure; and 

3. The procedure must be followed by the executive while depriving a person of his life or
liberty. 

This was a very mechanical and positivist interpretation of the principle laid down by the
judiciary. Thus, it was not under the power of the judiciary to check the validity of the law.
It could merely test the validity of the procedure followed to bring that law into force.

There came a shift in this approach with the landmark judgment given in Maneka Gandhi v.
Union of India (1978). In this case, a substantive meaning was given to the principle of
‘procedure established by law’ and the American doctrine of ‘Due process of law’ was given
a backdoor entry into the Indian Constitution. Due process of law not only checked the
validity of the procedure followed but also looked into the fairness of the law establishing
the procedure to deprive a person of his life or liberty. It highlighted that not only the
procedure must be fair and reasonable, but the law must also pass the test of
reasonableness. Thus, ‘procedure established by law’ was established as an extension of the
‘due process of law’. The Court opined that though the framers of our constitution
incorporated only ‘procedure established by law’, they did not stop us from progressing
towards ‘due process of law’ for the benefit of the citizens, which was the actual intention of
the makers. Thus, now, ‘procedure established by law’ is not only construed to check the
validity of the procedure that is depriving a person of his right under Article 21, but also the
law or statute which is authorising the executive to do so. 

Scope of Article 21 of the Indian Constitution

‘Life’ itself is a very wide term that cannot be summed up in a few words. It can not be
made complete by one or two elements. There are several such aspects that make life
complete and worth living. Thus, while talking about the scope of Article 21, it cannot
merely imply the simple act of living, which may even amount to an animal’s existence. In
order to live a fulfilling life, a person needs dignity, reputation, good health, a clean and
safe environment, livelihood, safety and security, shelter, privacy, and a lot more. Thus, the
scope of Article 21 is very broad. 

But it has not always been meant to be this way. It was only intended to protect a person’s
life and liberty, so none of them can be taken away arbitrarily by the state, except when
laws empower it. In India, we follow the concept of ‘Transformative constitutionalism’, i.e.,
subjective interpretation of the constitutional provisions to suit the needs of changing
society while adhering to the basic structural values. With time, when courts faced
questions as to what constitutes ‘life’ and what its elements are, our courts have taken a
progressive outlook by expanding the ambit of Article 21 and giving it new dimensions.

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Thus, Article 21 today is a canopy of rights that includes several elements that make life
meaningful. 

Elements of Article 21 of the Indian Constitution

Right to health and medical care

A healthy body is an indispensable requirement in order to live a fulfilling life. Our body is
responsible for the performance of different activities which form the basis of our life. If we
are not healthy or do not get proper and timely healthcare, then we would not be able to
live our life to the fullest as our activities shall be restricted by diseases and ailments. Thus,
in State of Punjab v. M.S. Chawla (1996), it was established that the right to health and
medical care fell within the ambit of the right to life guaranteed under Article 21.

In the case of Consumer Education and Research Centre v. Union of India (1995), the
health of workers was linked with their right to life under Article 21. It was observed that
the preamble to our Constitution seeks to deliver social justice to all. Social justice implies
everyone’s access to a liveable and meaningful life with minimum standards of health,
economic security, and civilised living. Thus, denial of their right to healthcare to the
workers would be tantamount to violating their fundamental right to life under Article 21. 

Right to life also imposes the duty on the state to preserve life. In Paschim Banga Khet
Mazdoor Samity v. State of West Bengal (1996), a person who was involved in a train
accident and had sustained severe injuries was denied treatment by all the hospitals under
the pretext of not having the requisite infrastructure and facilities for the treatment. The
Court held that by denying treatment to the patient, the government hospitals had violated
his fundamental right to life. Hence, they were held liable. Also, the right to emergency
treatment was also recognised by the court in this case. 

Therefore, the right to health and medical care is an important element of the right to life. 

Right to shelter 
As recognised in the case of Shantisar Builders v. Narayan Khimalal Totame (1990), the
right to life encompasses the right to food, the right to clothing, and the right to a decent
environment and accommodation to live in. The court also outlined the fact that one thing
that distinguished humans from animals is that humans require a shelter to live under.
Animals merely seek the protection of their physical boy, but for humans, shelter has a
wider connotation. It is important for overall development, i.e., physical, mental, and
intellectual growth. It is not important for everyone to have well-built, large, and
comfortable houses. Decent and reasonable accommodation is what is necessary. 

In the case of Rajesh Yadav v. State of U.P. (2022), the Supreme Court held that right to
shelter is a fundamental right under Article 19(1)(e) read with Article 21. Thus, it is the
duty of the state to grant housing sites for the residents. Articles 38 and 46 impose a

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positive duty on the state to make efforts to reduce income inequalities in order to
safeguard the basic needs of the people like food, clothing, and shelter. Therefore, under
Article 21 it is the state’s responsibility to make available reasonable places of shelter for
the needy people.

Right to clean and healthy environment 

Humans are directly and indirectly dependent on the environment for their survival. Most of
our basic needs are satisfied by the resources obtained from nature. The sustenance of our
life depends on the ecological system around us. Thus, any harm done to the environment
affects the lives of humans substantially. A polluted environment is an anti-thesis to our
right to life as we can never enjoy our life fully with polluted resources that make them
unfair for human consumption. 

That is why, in the case of Subhash Kumar v. State of Bihar (1991), it was observed that
the right to the enjoyment of pollution-free water and air came under the ambit of the right
to life under Article 21. Therefore, if any activity causes harm to the environment, recourse
can be taken to Article 32 in order to stop the cause of harm or pollution. 

Right to freedom from noise pollution 

Noise pollution is a form of a nuisance that can cause serious damage to human health. It
can cause irritation, annoyance, high blood pressure, damage ears, and disturb the sleep
cycle. Thus, the freedom from noise pollution forms another important element of the right
to life. It has been held that the right to live in an environment free from noise pollution is a
fundamental right guaranteed under Article 21 of the Indian Constitution in some landmark
cases like Free Legal Aid Cell Shri Sugan Chand Aggrawal alias Bhagatji v. Govt. of NCT of
Delhi and others (2001), and P.A. Jacob v.Superintendent of Police, Kottayam, (1993). 

Additionally, the matter again came in front of the Supreme Court recently where the use of
loudspeakers was in question. The issue was related to the noise pollution caused by the
use of loudspeakers in temples and mosques. The Court held that no one can be forced to
be the audience of the religious message being spread and the protection of religious
freedom cannot be availed here. Thus, it was observed that the resulting noise pollution
violated the right to life under Article 21. 

A similar judgement was also given by the National Green Tribunal while hearing a plea
regarding the noise pollution caused by gurudwaras in Hoshiarpur, Punjab. It was held that
a noise-free environment was a part of the right to life and also that its violation amounted
to a criminal offence. 

Right to privacy 
The concerns about the right to privacy were raised for the first time in the case of Kharak
Singh v. State of U.P. (1962). The main issue was related to the surveillance of the

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suspects. The Court linked the right to privacy with the right to protect life and personal
freedom. Thus, if surveillance was intrusive and gravely encroached upon the privacy of any
citizen, it violates both Articles 19(1)(d) and 21. 

In Naz Foundation v. Government of NCT of Delhi (2009), privacy was defined as “a private
space in which a man may become and remain himself.” Thus, it is basically the right to be
left alone. 

However, in Govind v. State of Madhya Pradesh (1975), Justice Mathew placed a caution on
the right to privacy by holding that it was not an absolute right. He held that fundamental
rights have their penumbral zones, and like any other fundamental right, the right to
privacy was also subject to reasonable restrictions on grounds of compelling public interest.
Therefore, reasonable intrusions like that from legislative action, administrative/executive
order, and judicial orders are permissible and do not violate the right to privacy under
Article 21.

Another landmark judgment on the right to privacy is Justice K.S. Puttuswamy (Retd) v.
Union of India (2018). The case was filed by a retired justice K.S. Puttuswamy, claiming
that the government’s scheme of introducing biometric-based identity cards to avail
government services and benefits was an infringement of the citizen’s right to privacy. The
honorable Supreme Court after listening to both sides held that the right to privacy was an
essential part of the right to life. It also outlined the ambit of the right to privacy upholding
that it included autonomy over decisions relating to personal choices (example, eating
beef), bodily integrity (example, reproduction and abortion rights), and even the protection
of personal information (example, health records). Along with this, the Court also expressed
that there was a need for the introduction of a data protection regime in India.  

Rights to education
For the first time, in the case of Mohini Jain v. State of Karnataka and Ors. (1992), the right
to education was recognised as a part of the right to life and personal freedom under
Article21.

Also, while hearing a petition on the validity of the Right to Education Act, which provided
free and compulsory education till the completion of primary school education for all
children between the age groups 6-14, the right to education was outlined as a part of the
right to life under Article 21. A three bench consisting of Chief Justice S.H. Kapadia, K.S.
Radhakrishnan and Swantanter Kumar held that education was instrumental in providing
the means to live a life with dignity and hence, it was an important facet of the right to life. 

Additionally, Articles 45 and 39(f) of the DPSPs provide that the state must make provisions
for affordable and accessible education for all. 

Education is the key to liberation and opens up the doors to a fulfilling life. With education,
other rights like food, shelter, and livelihood are also secured collaterally. This is because

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the right to education has also been added as a fundamental right with the insertion of
Article 21A by the 86th Amendment. 

Right to information 
Right to know was included under the ambit of Article 21 in the case of R.P. Ltd. v. Indian
Express (1988). The Court highlighted the importance of the right to information in a
participatory democracy. It was observed that getting to know the information regarding
various government workings and other issues that affect our rights as citizens is important
so that we are able to make an informed choice. Article 21 guarantees personal liberty and
freedom, but it can be exercised only when one has all the information affecting our
choices. Thus, in order to make truly free decisions, the right to information is essential. As
a result, the Right to Information Act, of 2005 was brought into force to secure this right of
the citizens. 

Right to a speedy trial 

In India, criminal cases have a history of being dragged on for years. The persons worst hit
by this trend are the under-trial prisoners. For years the case goes on and the person is
forced to spend time even greater than the punishment prescribed for that particular crime
in prison while the case is pending. This takes away crucial years from the life of a person.
In the end, even if the person is acquitted, those years spent in prison are never coming
back. This has caused overcrowding in the prisons. As a result, the prisoners are forced to
live in unhygienic conditions with no facilities. As is often repeated, justice delayed is justice
denied. This highlights the need for a speedy trial.

Consequentially, in the case of Hussainara Khatoon v. Home Secretary, State of Bihar

(1979), it was held that the right to a speedy trial was implicit in the right to life and
personal liberty under Article 21. When a person is imprisoned for a longer period than
required or is made to wait for the judgment for an unreasonable long period, it takes both
his right to live a life and his personal liberty. In this case, the writ of habeas corpus was
filed on behalf of several women, men, and children under-trial prisoners waiting for a
decision for years behind the bars. The court also highlighted the importance of easy access
to bail, more humane living standards, and a reduction in time from arrest to trial. 

Right to livelihood 
Initially, in the case of Re Sant Ram (1960) before the Maneka Gandhi judgment was
delivered, the view accepted was that the right to livelihood can be covered under Article
19, or even under Article 16 in a limited sense, but not under Article 21. Thus, it was
construed that the word ‘life’ did not include ‘livelihood’. 

But post-Maneka judgment, Article 21 was given a broad interpretation. Thus, in the case of
Board of Trustees of the Port of Bombay v. Dilipkumar Raghavendranath Nandkarni (1982),
the Court came to a conclusion that the word ‘life’ in Article 21 included ‘livelihood’ as well. 

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In the case of Olga Tellis v. Bombay Municipal Corporation (1985), also known as the
famous ‘pavement dwellers case’, it was observed that no person can survive or have a life
worth living without having the means of earning that living, i.e. having a means of
livelihood. It was also added that the state may not actively provide a means of livelihood
to every person, but it cannot take away someone’s right to livelihood, except according to
a fair and just procedure established by the law. 

Thus, in the case of DTC v. DTC Mazdoor Congress (1990), where an employee was laid off
without any notice and a valid reason, the court held it was violative of Article 21 as the
right to livelihood is a part of the right to life. 

Right to die 
It has always been a controversial question whether the right to life also includes the right
to die. The tussle between the right to life and the right to die started in the case of State of
Maharashtra v. Maruti Sripati Dubal (1986). The Bombay High Court held that the right to
life under Article 21 includes the right to die. Thus, Section 309 of the Indian Penal Code,
which penalised suicide was struck down for being unconstitutional. This judgment was
upheld by the Supreme Court in the case of P. Rathinam v. Union of India (1994). It was
observed that the right to life includes the right to live a dignified life and not to live a
forced life. It was also stated that suicide is not a crime but a cry for help, and hence does
not deserve punishment. 

Section 309 was an archaic law that criminalised ‘attempt to suicide’, i.e., anyone who
survived a suicide attempt could be booked under this Section. The basic idea was that the
right to life did not include the right to die. It was considered to be a crime against both the
state and religion. However, even though it was held to be unconstitutional, it continued to
remain in the Indian Penal Code. However, its scope was significantly reduced in with the
coming of the Mental Healthcare Act, 2017 which prescribed that it shall be presumed that
the person committing suicide was under severe stress unless proved otherwise and shall
not be tried under Section 309. 

However, this decision was overruled in Gian Kaur v. State of Punjab (1996). it was
observed that Article 21 preserves the natural right to life and suicide is not at all-natural. It
is an unnatural termination of life, which is the antithesis of the right to life. The court also
established a distinction between suicide and euthanasia. This case finally upheld that the
right to life includes the right to live with dignity, but only until the natural end of life.
Therefore, the right to life did not include the right to die. Thus. euthanasia was also not
recognised to be legal. The case of Aruna Ramchandra Shanbaug v. Union of India (2011)
proved to be a landmark judgment that for the first time recognised passive euthanasia in
India. Even though the plaintiff was denied euthanasia since she was not declared to be
brain dead, it was held that passive euthanasia could be administered with the prior consent
of the concerned High Court.

Finally, in the case of Common Cause v. Union of India (1999), it was recgonised that the
right to life encompassed the right to die with dignity. Thus, an adult with the requisite

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mental capacity to make an informed decision could refuse medical treatment or request for
withdrawal of life-support systems. The concept of ‘living wills’ was also introduced. 

Right to travel abroad

In Satwant Singh Sawhney v. Assistant Passport Officer, New Delhi (1967), Supreme Court
upheld that the right to travel abroad was an essential element of ‘personal liberty’ under
the right to life. 

This judgment was again upheld in the case of Maneka Gandhi v. Union of India (1978).
This case was the harbinger for the future board and liberal interpretations of Article 21. It
was in this case that for the first time the scope of Article 21 was widened and a subjective
interpretation was taken. The meaning of personal liberty was expanded to include the right
to travel abroad. Also, it was, in this case, the Apex court took a step toward ‘due process
of law’ from the ‘procedure established by law’. 

Right to free legal aid 

The right to free legal aid was held to be a fundamental right under Article 21 in the case of
Hussainara Khatoon and Ors. v. Home Secreatary, State of Bihar (1979). Justice P.N.
Bhagwati observed that free legal aid was an essential part of ‘reasonable, fair and just
procedure for anyone who is undergoing a trial and this is guaranteed by Article 39A and is
implied in Article 21. 

Article 21 guarantees the right to life and personal liberty, except against the procedure
established by the law. However, a person incapable of defending himself/herself against
the procedure established by the law is clearly deprived of his/her right under Article 21.
Free legal aid ensures that equal opportunity is provided to the downtrodden, poor, and
weaker sections of society to defend themselves and their right to life and liberty. 

Also, the right to free legal aid is enshrined in Article 39A by the 42nd Amendment Act
under the Directive Principles of State Policy. It states that the State must endeavor to
provide equal access to justice to everyone and free legal aid to the ones hindered by
economic or other disabilities. 

Right against handcuffing 

Usually, the accused and undertrials are handcuffed to prevent them from escaping.
However, it is not required in all cases. Over the years, it has been considered to be a
humiliating practice that restricts the freedom of an accused or undertrial who may even be
declared innocent by the court. Thus, in the case of Sunil Batra v. Delhi Administration
(1978), it was observed that Article 21 forbids the deprivation of personal liberty, except in
accordance with the procedure established by law. Handcuffing deprived a person of his
liberty and all the accused and undertrials must be given the minimum freedom of

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movement. Thus, the right against handcuffing was also included under the ambit of Article
21. 

Right against inhuman treatment 

Prisoners have been subjected to cruel and inhuman forms of punishment like handcuffing
and using chains and iron rods to punish them. Courts have taken notice of the fact that
such inhuman treatment was completely unjustified and violated Article 21. It has been
established that some forms of restraining instruments can be used but only in special and
restricted cases. In the case of Kadra Pehadiya v. State of Bihar (1980) where four
undertrial prisoners were chained to iron rods, the Apex Court denounced this practice as
inhuman and unjustified. The Court ordered the immediate removal of those chains. Also, in
Sunil Gupta v. State of MP (1990), the handcuffing of the accused who had voluntarily
surrendered and refused to bail out for public good was held to be inhuman in nature and
violative of Article 21. 

Right against sexual harassment 

In a recent case of Union of India and Ors. v. Mudrika Singh (2021), Justice D.Y.
Chnadrachud, and A.S. Bopanna recognised the right against sexual harassment as a part
of Article 21. It was held that the right against sexual harassment was entrenched in all
persons and is an important element of the right to life and dignity. Sexual harassment is a
grave crime that attacks the dignity of a person, thus attracting the application of Article
21. 

Also, in the landmark judgment of Vishakha v. State of Rajasthan (1997), Justice Verma
stated, “The meaning and content of the fundamental rights guaranteed in the Constitution
of India are of sufficient amplitude to compass all the facets of gender equality including
prevention of sexual harassment or abuse.” In this case, sexual harassment, particularly at
the workplace, was held to be violative of the right to equality, life, and liberty. Thus, it
breached Articles 14, 15, and 21 of the Indian Constitution. 

Right to sleep 
Interestingly, it has been held that the right to sleep is also a part of Article 21. The
Supreme Court, while ruling that the police action on the sleeping crowd in Ramlila Maidan

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amounted to a breach of their right, observed that the right to sleep was a crucial right.
Every citizen has a right to sound sleep as it is fundamental to the right to life. The Court
said that “sleep is essential for a human being to maintain the delicate balance of health
necessary for its very existence and survival. Sleep is, therefore, a fundamental and basic
requirement without which the existence of life itself would be in peril.” Thus,
acknowledging the health benefits of sleep for a human, the right to sleep had been made a
fundamental right under Article 21.

Right against solitary confinement 

Solitary confinement, as defined in Black’s Law Dictionary, refers to “the separate
confinement of a prisoner, with only occasional access of any other person, and that only at
the discretion of the jailer; in a stricter sense, the complete isolation of a prisoner from all
human society, and his confinement in a cell so arranged that he has no direct intercourse
with or sight of any human being, and no employment or instruction.”

Over the years, it has been denounced as an extreme form of torture that violates the
prisoner’s rights. In the case of Unni Krishnan and Ors. v. State of Andhra Pradesh and Ors.
(1993), solitary confinement was held to be violative of the right to life and personal
freedom granted under Article 21. It breaches basic human rights, capable of causing
mental illness, physical pain, and suffering. It degrades a person’s dignity and is a cruel
form of punishment. Thus, every prisoner has a right against solitary confinement as a part
of Article 21. 

Right to reputation 
In the case of the Board of Trustees of the Port of Bombay v. Dilipkumar Raghvendranath
Nadkarni (1983), it was observed that the right to reputation is an important facet of Article
21. Reputation is an important element of living a dignified life which is secured by the right
to life. Even though our constitution guarantees the freedom of speech and expression, it
cannot be misused to defame someone. Moreover, reasonable restrictions can be
constitutionally placed on this freedom. In fact, defamation is also a criminal offence under
Sections 499 and 500 of the Indian Penal Code. Thus, to ensure that everybody lives a
dignified life with a good reputation, the right to reputation has been included under Article
21. 

Right against public hanging 

In the case of Attorney General of India v. Lachma Devi and Ors. (1985), the practice of
public hanging was held to be violative of the right to life and personal liberty guaranteed
under Article 21 of the Indian Constitution. It was observed that it was a barbaric and
archaic practice that must be given up. It takes away a person’s dignity from him and is
certainly a ‘revolting spectacle’.  

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Right to water and electricity 

In a slew of judgments, various High Courts across the country have held the right to water
and electricity to be an essential element of the right to life under Article 21. The honorable
Kerala High while listening to a writ petition filed by two KESB employees stated that “water
and electricity are an integral part of the right to life within the meaning of Article 21 of the
Constitution of India.”

In another case, Madan Lal v. State of Himachal Pradesh (2018), a division bench led by CJ
Surya Kant and J. Ajay Mohan Goel held that water and electricity formed a part of the basic
necessities of life and hence cannot be separated from the right to life under Article 21. 

Rights of prisoners to have necessities of life

The word ‘life’ has been given a wide connotation by our judiciary. It equally applies to the
prisoners. In the case of Marie Andres v. Superintendent, Tihar Jail (1974), it stated by
Justice Krishna Iyer, “imprisonment does not spell farewell to fundamental rights although,
by a realistic re-appraisal, Courts will refuse to recognise the full panoply of Part III enjoyed
by a free citizen”. Thus, not even the stone walls and iron bars of the prison can deprive a
person of his fundamental rights. That implies that the prisoners have the protection of
Article 21. 

In the case of Francis Coralie v. Delhi Administration (1981), it was observed that ‘life’ has
multiple facets including adequate nutrition and food, clothing and shelter, access to
education, ability and opportunity of expressing oneself in diverse forms, move freely, and
interact with fellow human beings. Thus, all the prisoners have the right to these basic
necessities as a part of Article 21. 

Right against custodial harassment 

India has witnessed several instances of custodial violence. However, it has been recognised
that custodial violence is a violation and complete degradation of human dignity. What
makes it more aggravating is that it is inflicted by the state itself which is the so-called
protector of our rights.

In the landmark judgment of DK Basu v. State of West Bengal (1996), it was stated that
“worst violations of human rights take place during the course of an investigation when the
police with a view to secure evidence or confession often resorts to third-degree methods
including torture and adopt techniques of screening arrest by either not recording the arrest
or describing the deprivation of liberty merely as a prolonged interrogation.” This clearly
amounts to a violation of the right to life and dignity under Article 21. Thus, the Court laid
down detailed guidelines to protect the rights of the prisoners and prevent instances of
custodial harassment. 

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What is Article 21A of the Indian Constitution

Education is an important component of a meaningful life for any person. It liberates a
person from the shackles of ignorance and empowers him to achieve his desired goals.
Education is also an important factor in a nation’s progress. 

Initially, the right to education was not a part of the fundamental rights. Though it was
prescribed under Article 45 as a part of the Directive Principles of State Policy, it was not an
enforceable right. Finally, in 2002, Article 21A was added to Part III of the Indian
Constitution, and the right to education was made a fundamental right by the 86th
Amendment Act. 

Article 21A provided every child in the age group six to fourteen years with the right to free
and compulsory education. It has been reiterated several times that the right to education
flows from the right to life and it was finally manifested in the form of this article. 

However, there are certain drawbacks to this article as well. Firstly, it does not include the
children below the age of six years and the ones falling between 14-18 years of age.
Scientifically, 0-6 age is a highly impressionable age and maximum cognitive development
takes place in this age. Also, once a child completes education till he turns 14 and then
does not have enough financial resources to continue his further education, his education is
left in the middle and he cannot seek any good and stable employment on the basis of this
education. Nevertheless, Article 21A has marked a positive step in the direction of raising
the Indian literacy levels. It was after this Section was added that the Right to Education
Act was brought into force in 2009. 

Right to life in conflict with death penalty 

There has always been a conflict between the right to life and the death penalty. The death
penalty is inherently violative of the right to life. The validity, utility, and morality of the
death penalty have always been in question. There are several judicial decisions that deal
with this conundrum. 

Firstly, in the case of Jagmohan v. State of U.P.(1972), the death penalty was recognised as
valid under the constitutional provisions. It was held that it does not violate Articles 14, 19
and 21. This was because it took away someone’s right to live in accordance with the
procedure established by the law. 

However, in Rajindra Prasad v. State of U.P. (1979), the learned judge pleaded against
capital punishment. It was observed in this case that capital punishment was not justified
unless it can be shown that the criminal is extremely dangerous to society. 

Finally, the doctrine of ‘rarest of the rare’ cases was established in Bachan Singh v. State of
Punjab (1980). It was held that capital punishment was not in violation of the right to life
under Article 21 when done in accordance with the just, fair, and reasonable procedure

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established by a valid law. Also, it was observed that capital punishment must be given only
in the rarest of rare cases so that no innocent is sentenced to death. 

Is right to life an absolute right

No, the right to life guaranteed under Article 21 of the Indian Constitution is not an absolute
right. It is stated in Article 21 itself that life and personal liberty can be taken away as per
the procedure established by law. However, a shift came in this ideology with the famous
Maneka Gandhi judgment where it was held that not only the life and liberty is to be taken
away in accordance with the procedure established as per the prevailing law, but it should
also be just and fair, i.e., as per the due process of law. It should not be arbitrary or
oppressive. 

However, the right to life has been provided with additional protection, i.e. in the case of a
national emergency when all other fundamental rights are suspended, Article 21 along with
Article 20 are still functional. This implies that the right to life and liberty cannot be taken
away even when an emergency has been proclaimed in the country.  

Right to life in other countries 

The United States of America

The following amendments in the USA deal with the right to life and personal liberty:

1. Fourth Amendment– in 1791, the American citizens were granted rights against
‘unreasonable searches and seizures of their persons, houses, papers, and effects’. It
sought to protect the personal liberty of the citizens. 

2. Fifth Amendment– It prescribed that no one shall be compelled to be a witness against

himself or be deprived of liberty or property, without due process of law. 

3. Sixth Amendment– It granted the right to a speedy and public trial, and obtain witnesses
in favor when accused of any crime. 

4. Eighth Amendment– It stipulated that the state shall not inflict excessive fines and cruel
and unusual punishments on anyone. 

5. Fourteenth Amendment- It laid down that all persons born or naturalised in the US shall
not be deprived of life, liberty, or property without due process of law. 

One of the notable things here is that the US follows the principle of ‘due process of law’
and not the ‘procedure established by law’, as followed in India.  In the US, the courts have
wider powers to not only look into the validity of the procedure followed but also into the
reasonableness of the law that prescribes the procedure which deprives a person of his life
or liberty. After the Maneka Gandhi judgment, the Indian judiciary has also shifted its
approach towards ‘due process of law’. 

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The United Kingdom 

The earliest instance of the mention of the right to life in England was the Magna Carta of
1215, which proclaimed, “no freeman shall be taken, imprisoned, disseized, outlawed,
banished or in any way destroyed without a legal and valid proceeding, except in the law of
the land.” The Magna Carta was a powerful instrument of self-protection for the people
against the oppressive tyrants. 

Presently the right to life and liberty is available to all the people in the UK, regardless of
whether they are British citizens or not, by the virtue of the Human Rights Act of 1998.
Article 2 of the Act provides that no one shall be deprived of his/her life and proper
investigation must take place if someone dies under unexpected or suspicious
circumstances. Thus, the state is not allowed to breach this right, even under an
emergency, except only when it is absolutely necessary. Additionally, Article 5 guarantees
the right to liberty and security. It protects people from their freedoms being taken away
arbitrarily, except when the law prescribes it. 

Conclusion 
The right to life is one of the most significant human rights that safeguard not only one’s life
and liberty but also other elements of life like livelihood, dignity, shelter, privacy, health,
etc. that make living worthwhile. It is not absolute and can be curtailed by the procedure
established by law. However, it has been upheld by the courts that not only the procedure
followed should be valid, but it should also be reasonable and established by a valid and
just law. In India, Article 21 guarantees the right to life and personal dignity and has been
given a wide interpretation by our judiciary. It is also available in other countries and under
international statutes. Also, it has come into controversy several times on issues like capital
punishment and euthanasia. Nevertheless, the right to life has always triumphed in the
debate. 

FAQs

What is Article 21?

Article 21 of the Indian Constitution states that every person has got the right to life and
personal liberty and it cannot be taken away except in accordance with the procedure
established by the law.

Is the right to life an absolute right?

No, the right to life is not an absolute right and can be taken away as per the procedure
established by law. However, it is not suspended even during an emergency. 

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Does the right to life include the right to die?

It has been held that the right to life includes the right to live with dignity, and thus a
person who is suffering from an incurable disease or is being kept alive through life support
systems can avail his right to die, by the means of a living will. It is only passive euthanasia
that is recognised in India. 

What is the difference between the ‘due process of law’

and the ‘procedure established by the law’?
The ‘due process of law’ is an American concept that prescribes that the right to life can be
taken away in accordance with a law that is just and reasonable. However, the ‘procedure
established by law’ prescribes that the right to life can be taken away in accordance with
the procedure established by law, i.e. only the validity of the procedure followed is taken
into consideration, and not the justness and fairness of the law establishing that procedure.
Indian judiciary made a departure from the ‘procedure established by law’ to the ‘due
process of law’ in the Maneka Gandhi judgment. 

References 
1. https://www.northeastlawjournal.com/post/procedure-established-by-law 

2. https://www.britannica.com/topic/human-rights 

3. https://www.lawctopus.com/academike/article-21-of-the-constitution-of-india-right-to-
life-and-personal-liberty/

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