Model Answer
0 min readIntroduction
The Constitution of India, adopted in 1950, is often described as a ‘living instrument’ due to its inherent flexibility and capacity to adapt to changing societal needs and values. This dynamism stems from its provisions for amendment, coupled with a robust judicial review mechanism. The Supreme Court, through its interpretations, has significantly expanded the scope of fundamental rights, particularly Article 21 – the right to life and personal liberty – transforming it from a narrow definition to encompass a wide range of rights essential for a dignified human existence. This evolution reflects the Constitution’s commitment to a progressive society, constantly striving for justice, liberty, equality, and fraternity.
Expanding Horizons of Article 21
Initially, Article 21 was interpreted restrictively, focusing solely on physical existence. However, through a series of landmark judgments, the Supreme Court has broadened its scope considerably.
Early Interpretations & Procedural Safeguards
The initial focus was on ensuring procedural fairness. The Maneka Gandhi v. Union of India (1978) case was pivotal. The Court held that Article 21 not only protects life but also personal liberty, and this liberty cannot be curtailed except according to ‘just, fair and reasonable procedure established by law.’ This introduced the concept of procedural due process, moving away from the earlier ‘procedure established by law’ standard.
Right to Livelihood & Dignified Life
The Court further expanded Article 21 to include the right to livelihood as an integral part of the right to life. In Olga Tellis v. Bombay Municipal Corporation (1985), the Court ruled that the right to livelihood is essential for a life with dignity and cannot be arbitrarily deprived. This case highlighted the importance of protecting the means of survival for marginalized sections of society.
Environmental Rights & Health
Recognizing the link between a healthy environment and the right to life, the Court has included environmental protection within the ambit of Article 21. Cases like M.C. Mehta v. Union of India (1987), concerning pollution control, demonstrate this. Similarly, the right to health has been recognized as a fundamental right under Article 21, obligating the state to provide adequate healthcare facilities. Paschim Banga Khet Mazdoor Samity v. State of West Bengal (1996) emphasized the state’s duty to maintain public health.
Right to Education & Information
The right to education was initially recognized as a directive principle, but the 86th Amendment Act (2002) made it a fundamental right under Article 21A. The Court has also held that the right to information is an integral part of the right to life and personal liberty, enabling citizens to participate meaningfully in democratic processes. SP Gupta v. Union of India (1982), while later partially overruled, initially contributed to this understanding.
Personal Autonomy & Bodily Integrity
Recent judgments have focused on personal autonomy and bodily integrity. The K.S. Puttaswamy v. Union of India (2017) case declared the right to privacy a fundamental right, stemming from Article 21. This landmark judgment has far-reaching implications for data protection and individual freedoms. Furthermore, the decriminalization of Section 377 of the Indian Penal Code (Navtej Singh Johar v. Union of India, 2018) affirmed the right to personal choice and dignity, again rooted in Article 21.
Right to Die with Dignity & Passive Euthanasia
The Court has also addressed end-of-life issues, recognizing the right to die with dignity under Article 21. In Common Cause v. Union of India (2018), the Court legalized passive euthanasia under strict guidelines, allowing individuals to refuse life-sustaining treatment in certain circumstances.
| Case Name | Year | Key Principle Established |
|---|---|---|
| Maneka Gandhi v. Union of India | 1978 | Procedural Due Process under Article 21 |
| Olga Tellis v. Bombay Municipal Corporation | 1985 | Right to Livelihood as part of Right to Life |
| K.S. Puttaswamy v. Union of India | 2017 | Right to Privacy as a Fundamental Right |
| Common Cause v. Union of India | 2018 | Legalization of Passive Euthanasia |
Conclusion
The expanding horizons of Article 21 demonstrate the Constitution’s remarkable capacity for adaptation and its commitment to a progressive society. The Supreme Court, through its dynamic interpretations, has transformed this fundamental right into a powerful instrument for social justice and individual empowerment. This ongoing evolution underscores the Constitution’s status as a ‘living instrument,’ capable of responding to the changing needs and aspirations of the Indian people, ensuring a life of dignity and liberty for all. The future will likely see further expansion of Article 21, addressing emerging challenges and safeguarding fundamental human rights in a rapidly evolving world.
Answer Length
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