Question

“Right to life under Article 21” of the Indian Constitution does not include “Right to die”. This observation was made by the Supreme Court in which case ____?

• A. P. Rathinam v. Union of India
• B. NALSA v. Union of India
• C. Gian Kaur v. State of Punjab
• D. Aruna Shanbaug v. Union of India

Hint:

When studying constitutional law, remember that the interpretation of fundamental rights can evolve, as seen in the \textit{Gian Kaur} case, where the right to life was clarified in the context of assisted suicide.

Answer 1

The Correct Option is C

The Supreme Court in the case of Gian Kaur v. State of Punjab (1996) held that the "Right to Life" under Article 21 of the Constitution does not include the "Right to Die." The Court made this observation in the context of euthanasia, stating that the right to life does not extend to include the right to terminate one’s own life.

Answer 2

The observation that the “Right to life under Article 21” of the Indian Constitution does not include the “Right to die” was made by the Supreme Court in the landmark case of Gian Kaur v. State of Punjab (1996).

Background of the Case:
Gian Kaur and her husband were convicted under Section 306 of the Indian Penal Code (abetment of suicide). They challenged the constitutional validity of Section 306 by arguing that the “Right to die” is a part of the “Right to life” under Article 21, and therefore, abetment of suicide should not be punishable.

Supreme Court’s Judgment:
The Supreme Court overruled the earlier decision in P. Rathinam v. Union of India, which had held that the “Right to life” included the “Right to die.”
In Gian Kaur v. State of Punjab, the Court held:
- The “Right to life” is a natural and inherent right, and it cannot logically include the opposite — i.e., the right to die.
- Article 21 guarantees protection of life and personal liberty, but it does not include the right to end one's life.
- Suicide and abetment of suicide are not protected under Article 21, and Section 306 IPC is constitutionally valid.

Impact:
This judgment settled the legal position that while the “Right to life” is fundamental, it does not extend to the right to take one’s own life. It clarified the interpretation of Article 21 in the context of euthanasia and suicide laws.

Conclusion:
The Supreme Court held in Gian Kaur v. State of Punjab that the “Right to life under Article 21” does not include the “Right to die.”

Therefore, the correct answer is: Gian Kaur v. State of Punjab.