The Right to Life is a fundamental right and a constitutional concept enshrined in Article 21 of the Constitution of India, which states: "No person shall be deprived of his life or personal liberty except according to procedure established by law." This provision has been a part of the Constitution since its commencement on January 26, 1950, and applies to all persons, including citizens and non-citizens. The initial, narrow interpretation in A.K. Gopalan v. State of Madras (1950) held that "procedure established by law" meant a state-made law, even if arbitrary.
The concept was revolutionized by the Supreme Court's judgment in Maneka Gandhi v. Union of India (1978), which ruled that the procedure established by law must be "just, fair, and reasonable," effectively introducing the American concept of "due process of law" into Article 21. This judgment linked Article 21 with Article 14 (Equality before law) and Article 19 (Six freedoms), establishing that a law restricting life or liberty must satisfy the tests of all three articles. The judiciary has since expanded the scope of "life" beyond mere animal existence to include the right to live with human dignity, which encompasses rights like the right to livelihood (Olga Tellis v. Bombay Municipal Corporation, 1985), the right to a clean environment (Subhash Kumar v. State of Bihar, 1991), and the right to privacy (Justice K.S. Puttaswamy v. Union of India, 2017).
A significant recent change is the recognition of the right to die with dignity through passive euthanasia, which was legalized in Common Cause v. Union of India (2018), allowing for advance directives. Furthermore, the Supreme Court recently recognized that the right against adverse effects of climate change is derived from Article 21 in Ranjitsinh Chisotia v. Union of India (2024). The right to life is also connected to Article 21A, which was inserted by the 86th Constitutional Amendment Act, 2002, to guarantee free and compulsory education to children aged 6 to 14 years, a right previously derived from Article 21. The protection of Article 21 cannot be suspended even during an Emergency, a safeguard added by the 44th Constitutional Amendment Act, 1978.