Introduction
Article 21 of the Indian Constitution states: "No person shall be deprived of his life or personal liberty except according to procedure established by law." Although brief, this provision has been interpreted expansively by the Supreme Court to include a wide spectrum of human rights.
Landmark Cases
1. Maneka Gandhi v. Union of India (1978)
The Supreme Court held that the procedure under Article 21 must be "just, fair and reasonable." This judgment transformed Article 21 from a narrow procedural right into a substantive guarantee.
2. Olga Tellis v. Bombay Municipal Corporation (1985)
The Court recognized the right to livelihood as part of the right to life, declaring that the eviction of pavement dwellers without alternative arrangements violated Article 21.
Modern Interpretations
- Right to privacy (K.S. Puttaswamy v. Union of India, 2017)
- Right to a clean environment
- Right to dignity
- Right to die with dignity (passive euthanasia)
"The right to live is not merely a physical right but includes within its ambit the right to live with human dignity." — Justice Bhagwati
Conclusion
Article 21 remains the most dynamic and litigated provision of the Constitution. Its evolution mirrors India's journey towards a rights-based democracy.
