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Constitutionalizing the Right to Die with Dignity: ACritical Analysis of Harish Rana v. Union of India (2026)

Authored By: Pragati Kumari

University of Allahabad

Abstract 

The right to die with dignity in India has changed from a discussion about bioethics to a part of the Right to Life under Article 21 of the Indian Constitution. This paper looks at how the courts have developed the rules for end of-life care in India from the idea that life’s sacred to recognizing that individuals have autonomy and dignity in 

death. It carefully examines the Supreme Court decision in Harish Rana v. Union of India which was the first time passive euthanasia was actually used in India under the new laws that came after the Common Cause case. 

This decision is important because it says that Clinically Assisted Nutrition and Hydration including feeding through devices is a kind of medical treatment that can be stopped if it is not helping the patient as long as there are safeguards in place. The Court reminded us that in these cases we need to think about what’s best for the patient especially if they are in a Permanent Vegetative State and will not get better. The Court also created a system for doctors to review these cases, which makes things clearer for hospitals and families. 

This paper also compares how India handles euthanasia, which is mostly decided by judges and has restrictions to countries like the Netherlands and Canada where there are laws that cover end-of-life decisions. It points out that even though the courts have made progress India still relies much on guidelines made by judges, which can cause delays and inconsistent decisions. 

The study also talks about issues, such as the rights of people with disabilities and the problem of deciding what “quality of life” means. In the end the Harish Rana decision is a step forward in interpreting the constitution with compassion. However India needs laws that specifically address end-of-life care so that people can die with dignity, autonomy and protection from abuse. The right to die with dignity, in India needs to be protected by laws that make sure everyone is treated fairly and with respect. 

Key words 

Article 21, Right to Die with Dignity, Passive Euthanasia, Harish Rana v. Union of India (2026), Common Cause v. Union of India, Clinically Assisted Nutrition and Hydration (CANH), Advance Medical Directives, Living Wills, Best Interest Standard, Permanent Vegetative State (PVS), Substituted Judgment, Palliative Care, Bharatiya Nyaya Sanhita (BNS), Individual Autonomy, Bioethics, Sanctity of Life, Quality of Life. 

INTRODUCTION 

The right to die with dignity is connected to law, bioethics and moral philosophy. InIndia this right is not a right but is part of the right to life under Article 21 of the Constitution¹. 

The right to life is not about living it also includes dignity, autonomy and personal freedom. Judges have interpreted the meaning of “life” in a way going beyond just existing². They have said that life is not about being alive but also about living with dignity. The right to die with dignity is a part of this.It is linked to the right to life. Is not a separate issue. The Constitution and judges have shaped this right over time. The right to

die with dignity is closely tied to how we understand life. Life is not about existing but, about living in a way that is meaningful.The right to die with dignity is part of this life. 

The debate on euthanasia centres around two ideas: the importance of preserving life and a persons right to make choices.The importance of preserving life says that life should be saved at all costs.On the hand the idea of individual autonomy says a person has the right to say no to medical treatment that only makes them suffer more with no chance of getting better. In India courts have started to look at each case based on what’s best, for the patient focusing on their dignity and well-being especially when they are very sick and cannot get better. 

The courts now try to balance these two ideas. 

  • This approach looks at the patients quality of life. What they want. 
  • Euthanasia cases are decided based on the patients interests. 

The goal is to respect the patients wishes while also preserving life. 

The right to die with dignity in India has grown through court decisions. 

In Gian Kaur versus State of Punjab (1996) the Supreme Court said that the right to life does not mean the right to die³.It also said that dignity in death is part of dignity in life. 

* This idea was further developed in Aruna Shanbaug versus Union of India (2011). * There the court allowed euthanasia under strict supervision. 

The court again said in Common Cause versus Union of India (2018) that the right to die with dignity is part of the right to life under Article 21. The court also supported Advance Medical Directives also known as living wills. Even though the court supports the right to die with dignity it is not easy to implement euthanasia.There are steps to follow and it takes a long time.This has created a gap between the law and its implementation. This research paper looks at the court decisions that led to the implementation of euthanasia in India. It focuses on the changing laws, about end-of-life decisions. The paper also talks about the challenges in making sure that the right to die with dignity is implemented properly. The right to die with dignity and passive euthanasia are issues. The right to die with dignity and passive euthanasia need to be implemented. 

The Evolution of Euthanasia Jurisprudence in India 

The Indian courts have changed a lot in the way they think about end-of-life care. At first they thought that life was very important and should be saved at all costs. This is because of what it says in Article 21 of the Constitution.⁷ 

In the beginning even people who tried to kill themselves were treated like criminals. The courts did not think about it as a matter of rights. 

The courts started to think with the case of P. Rathinam v. Union of India in 1994. The Supreme Court said that people have the right to decide if they want to live or not.. This did not last long. In 1996 the Supreme Court said something in the case of Gian Kaur v. State of Punjab¹. They said that the right to life does not mean you have the right to die. However they also said that people should be able to die with dignity especially if they are very sick and cannot get better.

A big change happened in 2011 with the case of Aruna Shanbaug v. Union of India¹¹. The Supreme Court allowed something called euthanasia. This means that doctors can stop treating someone who’s very sick and will not get better. The Court said that this is different from euthanasia which is still against the law. They also said that the High Court has to agree before this can happen to make sure it is in the interest of the patient. 

The Indian courts kept thinking about end-of-life care and in 2018 they said that people have the right to die with dignity. This is part of what it says in Article 21 of the Constitution. They also said that people can make something called a living will which says what they want to happen if they get very sick¹². The Court made a system to control how life support is stopped. 

But it was not easy to follow these rules so they had to be simplified in 2023.¹³ This helped to make end-of-life care more dignified. Later in the case of Harish Rana v. Union of India in 2026 the Court showed how passive euthanasia could actually work in life.¹This was a step forward, in making sure that end-of-life care is dignified. 

The Indian courts and end-of-life care have come a way. End-of-life care and the Indian courts are still changing. Indian jurisprudence regarding end-of-life care and the Indian courts are getting better. 

Constitutionalisation of the Right to Die with Dignity in India 

Right to die with dignity in India is protected under Article 21 of the Constitution of India¹. The Article states that, “No person shall be deprived of his life or personal liberty except according to procedure established by law.” Over a period of time the Supreme Court has reinterpreted this legislation by stating that right to life includes a right to die with dignity but not right to die. 

It states a different perspective taken by the court towards the definition of right to life; the right not to merely exist, but live with dignity and autonomy¹. In fact the court has stated that life is not only to live, but to live with dignity. 

In some instances, maintaining someone alive by artificial means violates the dignity of human being; especially when it becomes evident that there is no chance of survival. It was the concept that led to establishing the right to die with dignity. Right to die with dignity became part of the Indian Constitution as the court is of the view that right to die with dignity is an aspect of right to live with dignity. 

The debate regarding the right to die with dignity took its initial form in the case of Gian Kaur v. State of Punjab in 1996 wherein the Supreme Court held that right to die is not guaranteed by Article 21 of the Constitution of India, but the right to die with dignity is part of right to live with dignity.¹⁷ 

In Aruna Shanbaug v. Union of India in 2011, the court had accepted euthanasia (discontinuation of medical treatment under certain guidelines¹). Right to die with dignity was made a part of the Indian Constitution in Common Cause v. Union of India in 2018¹. The court had also made a provision that people have the right to make living wills. A living will contains one’s own directions on future treatment if he/she becomes incapable of communicating them. 

The regulations concerning living wills were further amended in the year 2023 simplifying the process and then in the year 2026, the Supreme Court applied these regulations to help a terminally ill patient, thereby holding that the keeping him alive by machine was violating the human dignity, as there was no chance of recovery².

The right to die with dignity has been restricted to euthanasia only, i.e. Withdrawing medical treatment but not the actual act of committing suicide. The court tried to strike balance between the interest of the state in maintaining the life and the interest of the individual’s autonomy in regard to the process of dying. 

The right to die with dignity is considered as an inseparable component of the right to life which is based on the assumption that individuals should be given the right to die with dignity, just like they are expected to live with dignity, the right to die with dignity forms an integral part of the Indian Constitution in Article 21 of the Indian Constitution. 

Harish Rana v. Union of India: The First Judicially Sanctioned Implementation 

Harish Rana v. Union of India (2026) stands out as the first real example of passive euthanasia being carried out in India²¹. Harish, an engineering student, had a terrible fall in 2013 that left him with a severe brain injury. He spent over thirteen years in a permanent vegetative state, kept alive only through nutrition and hydration given by a PEG feeding tube. 

When the case first went to the Delhi High Court in 2024, Harish’s family asked to stop treatment. The court shot down the request, saying Harish wasn’t technically terminally ill since he wasn’t on a ventilator.²² They argued that removing the feeding tube would basically be starvation—not passive euthanasia. That decision made it clear the law didn’t really cover people in irreversible states who don’t need machines to breathe. 

Later, the Supreme Court stepped in. In 2025, they took a closer look, treating the case as a big test for the Common Cause framework²³. After an evaluation by AIIMS confirmed Harish’s condition would never improve and the feeding tube just kept his body functioning, the Supreme Court made their decision. In March 2026, they allowed the withdrawal of life support, including the feeding tube. 

This ruling mattered a lot. It didn’t just put passive euthanasia into practice—it also spelled out where artificial nutrition fits into the law, and made the process for end-of-life decisions in India a lot clearer²

Defining Clinically Assisted Nutrition and Hydration (CANH) 

In Harish Rana v. Union of India (2026), the key question was how to legally define Clinically Assisted Nutrition and Hydration (CANH). For years, both lawyers and doctors couldn’t agree — is feeding a patient through a tube just “basic care,” like washing or hygiene help, or is it real “medical treatment,” like using a ventilator or dialysis? This isn’t just wordplay; the answer decides if such feeding can be legally stopped under passive euthanasia rules. 

The Supreme Court settled the debate by saying that CANH—whether it’s feeding through a PEG tube or giving nutrition straight into the bloodstream—is medical treatment. The judges explained that this kind of feeding isn’t something natural or routine. It’s a medical process from start to finish: doctors have to assess, professionals supervise, and everyone has to weigh the ongoing risks and benefits. So, it’s a form of life support, which means doctors can withdraw it, but only if they follow strict legal guidelines. 

Why does this matter so much? Well, according to the rules in the Common Cause case, only medical treatments—not basic care—can be withdrawn in situations where a patient’s condition won’t ever improve.²By calling CANH a medical treatment, the Court cleared up past confusion. They said stopping tube feeding isn’t “starvation,” as the Delhi High Court once believed. It’s simply allowing the disease to take its course without extra medical interference.

This decision fills a big legal gap, especially for patients who aren’t on ventilators but survive only because of artificial nutrition. Now, their cases fit into the same framework used for other end-of-life medical decisions. In the end, the Court’s approach gives real meaning to dignity under Article 21 of the Constitution, making sure that patients aren’t forced to endure medical procedures when those treatments don’t actually help them anymore.²⁶ 

The Best Interest Standard and Substituted Judgment 

When a patient can’t make decisions for themselves and hasn’t left an Advance Medical Directive, the Supreme Court steps in with the “best interests” principle to decide if life-sustaining treatment should keep going. In the 2026 case of Harish Rana v. Union of India, the Court made it clear: this isn’t just about whether treatment is useless from a medical standpoint. It’s a broad, thorough look at everything that matters²

The judges look at three main things. First, the medical stuff—whether the condition’s irreversible, how invasive the treatment is, and how much physical hardship the patient goes through because of it. Second, they factor in the patient’s personal world: what the person valued, believed, or wanted in the past and present, and their general emotional outlook. Third, the judges step back and consider the patient’s overall welfare— including dignity and quality of life. 

The Court also uses something called the substituted judgment standard. Here, they basically try to put themselves in the patient’s shoes and ask, “What would this person choose if they were able to decide right now?” In Harish Rana’s case, the judges paid attention to his life before the accident—how he loved sports and kept fit. From that, they figured he wouldn’t have wanted to keep living in a state where he was permanently unconscious and totally dependent on others. 

This way, even if the patient hasn’t left direct instructions, the decision tries to honor both dignity and autonomy. 

International Comparative Analysis of Right to Die Laws 

India’s approach to the right to die with dignity sits on a narrow ledge compared to the broad spectrum of global laws on end-of-life decisions. Different countries have taken wildly different paths—some with liberal, open approaches to euthanasia, others with tight controls. India, so far, has stuck to a cautious, limited framework. 

Let’s start with the Netherlands and Belgium. The Dutch were the first to pass a law allowing euthanasia—the Termination of Life on Request and Assisted Suicide Act, back in 2002². Here, doctors can carry out euthanasia or assist suicide, but strict rules apply. Patients must clearly ask for it, suffer unbearably with no hope of getting better, and go through an independent medical review. It all hinges on personal choice, seeing euthanasia as part of someone’s freedom over their own life. 

Belgium followed the Dutch model that same year and even took it further by including exceptional cases involving minors—again, only with tough psychological and medical checks. For both countries, the focus isn’t just on being terminally ill. It’s about suffering—physical or psychological—that’s unbearable. 

Canada took its own road after the Supreme Court’s Carter decision in 2015, setting up the Medical Assistance in Dying (MAID) system². Both euthanasia and assisted suicide are allowed, but rules are clear. In 2021, the law expanded to let people apply even if their death isn’t ‘reasonably foreseeable,’ as long as they face serious, incurable suffering³. With this, Canada leaned further into personal autonomy, but always with legal and medical safeguards.

Switzerland stands out with its unique approach. Assisted suicide is legal if there’s no selfish motive, thanks to Article 115 of the Criminal Code³¹. Organizations like Dignitas operate within this space, but the law draws a firm line—doctors can’t administer the life-ending medication themselves. Only patients can take that last step, making a clear distinction between helping and actively ending a life. It’s about autonomy, but with strict boundaries. 

Turn back to India, and the contrast is plain. India only allows passive euthanasia, and even that is based on Supreme Court judgments, not a specific law. Unlike countries with written statutes and clear procedures, India relies on constitutional interpretation to protect dignity at the end of life. The lack of a dedicated law makes things murky and uncertain. If anything, this comparison shows how urgent it is for India to develop a real, well-defined legal framework—one that respects autonomy and dignity but still guards against abuse. 

The Role of Palliative Care in the Withdrawal Framework 

One of the most important — and really, compassionate : parts of the Supreme Court’s judgment in Harish Rana v. Union of India (2026) is its demand that palliative care isn’t an afterthought when someone’s life support is withdrawn³². The court drew a clear line: stopping life support doesn’t mean leaving someone to fend for themselves. Instead, it’s got to be a careful, thoughtful process where medical supervision and ethics lead the way, making sure the person keeps their dignity right through the end. 

In Harish Rana’s case, the court ordered his transfer to a dedicated palliative care unit at AIIMS³³. This wasn’t just a bureaucratic move — it’s about giving the withdrawal process structure and clarity, so the patient isn’t left dealing with pain, panic, or breathing problems as life winds down. The court said, look, proper pain control and anxiety meds are essential. It’s not just about deciding to end aggressive treatment — it’s about making sure the way it ends is humane and as comfortable as possible. 

This really shifts the old goal in medicine. It’s not just about squeezing out a few more days; it’s about giving people a pain-free, dignified way to say goodbye. The court made it crystal clear: doctors’ duty doesn’t end until biological death actually occurs³

When it comes to practical lessons for ICU teams, the Harish Rana decision sets a new baseline. First off, it pushes for clear, consistent communication between doctors and families. Early, regular meetings where everyone lays their cards on the table matter — that’s how you build trust and avoid surprises. 

Next, the court placed a big spotlight on prognosis. The medical team needs to work together and deliver a united message. No mixed signals or doctors second-guessing each other in front of worried families — just one clear, honest assessment. 

The ruling also says the ICU should feel different when someone is at the end of life. Turn off non-essential monitors, stop unnecessary poking and prodding, and drop the urge for aggressive treatments. Let families visit more freely, so they have time and space for goodbyes. 

One last thing from the court: hospitals shouldn’t use “Left Against Medical Advice” as a loophole. That’s just a way of sidestepping proper palliative care, dumping responsibility on families who aren’t equipped for it. Patients deserve real support, right up to the very end. 

Criminal Law Implications and Legal Protections

Doctors in India have always worried about getting into legal trouble when making end-of-life decisions. For years, the Indian Penal Code (IPC) left a lot of uncertainty—especially when it came to stopping life-sustaining treatment. The new Bharatiya Nyaya Sanhita (BNS) has replaced the old code, but that fear hasn’t disappeared overnight.³So, a lot of doctors keep patients on treatments they know are pointless, just to avoid ending up in court. 

Suicide laws have complicated things further. Sections 309 and 306 of the IPC were big sources of anxiety during end-of-life care³. Section 309 punished attempts at suicide, and Section 306 targeted anyone accused of helping someone else end their life. Things shifted when the Mental Healthcare Act, 2017 came along. Section 115 of that law presumes anyone trying to commit suicide is under severe stress and generally decriminalizes those attempts.³⁷ 

Then came the Harish Rana v. Union of India (2026) case, which finally brought some clarity.³The court said stopping life-sustaining treatment in cases where recovery isn’t possible—like a permanent vegetative state— isn’t the same as abetting or attempting suicide. The judges made it clear: choosing to withdraw care isn’t what causes death. It’s a legal, medically justified decision to stop doing what no longer helps. 

There’s a critical difference here between active and passive euthanasia. Active euthanasia requires a doctor to do something that directly causes death. Passive euthanasia is about not intervening any further—either by not starting or by withdrawing treatment that has no benefit. The new criminal code would consider any direct act to cause death as murder or culpable homicide, but courts say when a medical board recommends withdrawing treatment and the family agrees, doctors commit no crime. They’re just following accepted medical norms and upholding the right to dignity under Article 21 of the Constitution.³⁹ 

Thanks to this judgment, doctors now have real legal protection. If they follow proper procedures for end-of-life care, they won’t risk criminal charges for simply respecting a patient’s wishes. The ruling recognizes passive euthanasia as lawful and constitutional, making it that much easier for doctors to do what’s right, without fear hanging over their heads. 

Critical Perspectives: Ableism and Disability Rights 

The Harish Rana v. Union of India (2026) case pushed the boundaries of end-of-life rights in India, but it hasn’t escaped tough criticism—especially from those who care about disability rights and medical ethics⁴⁰. Sure, the Supreme Court moved forward on the right to die with dignity under Article 21. But the way the judgment talks about dignity, autonomy, and vulnerability still leaves a lot of people uneasy. 

Let’s start with ableism. The court leaned on a “best interests” model and allowed non-voluntary passive euthanasia. On paper, that sounds measured. In reality, critics say, this approach is loaded with ableist undertones. When judges describe life in a permanent vegetative state as “mere biological existence” or “undignified survival,” it echoes an uncomfortable message: that lives with profound disability, even with consciousness or meaningful relationships, somehow count for less. Disability rights advocates point out the ruling never really grapples with the Rights of Persons with Disabilities Act, 2016 or India’s promises under the UN Convention on the Rights of Persons with Disabilities¹’². Skipping these conversations makes it too easy to slip into the assumption that dependence or severe impairment equals a life less worth living. 

Then there’s the classic slippery slope worry. Critics say letting doctors withdraw Clinically Assisted Nutrition and Hydration (CANH) could lead courts and caregivers to stretch those rules. If “permanent vegetative state” is the current boundary, what’s to stop future decisions from including advanced dementia or serious

neurological conditions? When the line between “no hope” medically and “life not worth living” starts to blur, decisions turn dangerous. 

Not everyone is buying the slippery slope panic. Supporters of the judgment say the Supreme Court’s safeguards are tight. There’s the two-stage medical board, judicial checks, and required ethical review—built-in hurdles to stop abuse or overreach³. 

In the end, this judgment underlines an ongoing battle in Indian law: how do you honor personal autonomy while protecting vulnerable people? The Court wants to respect dignity by letting families withdraw treatment when it’s futile. But critics aren’t saying stop progress—they’re asking for a broader, more inclusive idea of dignity, one that doesn’t treat disability or dependence as a lesser way to live. 

The Procedural Gap and the Need for Statutory Law 

The Harish Rana judgment made it clear that India still has a big gap in its laws. The Supreme Court has set up a solid framework, but it’s all based on judge-made guidelines, not actual statutes. 

Why We Need a Law  

Both the Court and legal policy experts keep asking the Union Government to pass a proper law about end-of life care. If there’s a clear statute, everyone follows the same procedures. That means less confusion, fewer court cases for each individual situation, and a more straightforward path for people seeking a dignified death across India. Plus, a law would ease the burden for doctors, especially in smaller cities. Right now, many hesitate or avoid helping because they’re scared they’ll get tangled up in legal trouble. 

Digital Integration  

People also want to make Advance Medical Directives easier to access by tying them to digital health systems like the Ayushman Bharat Health Account (ABHA). If your wishes are stored there, emergency physicians can see them instantly, no matter where you are. It’s a big step toward truly protecting someone’s dignity right up to their final moments⁴⁴

Conclusions and Recommendations 

The way end-of-life law has changed in India, especially with the 2026 Harish Rana v. Union of India case, shows a big shift toward a legal system that puts real weight on compassion, autonomy, and dignity. Now, the right to die with dignity isn’t just an idea—it’s built right into Article 21 of the Constitution⁴⁵. Life, under the law, isn’t just about continuing to breathe. It’s about quality, about autonomy, about whether that life is actually worth living for the person experiencing it. 

Things have moved a long way from a time when the main legal focus was to keep everyone alive at all costs. Now, the courts recognize medical reality. They get that sometimes, no matter what you do, recovery just isn’t possible. The Harish Rana judgment takes this principle and turns it into clear rules—laying out what steps need to be taken and making sure that medical ethics guide every decision. 

So, what needs to happen next? For hospitals, the best step is to set up permanent panels of qualified doctors. That way, when tough end-of-life situations come up, there’s no scramble to find experts. These panels can step in quickly, keep things running smoothly, and make sure protocols are applied fairly. Clear hospital guidelines should back this up so everyone knows what to expect.

As for lawyers, it’s time to push for an actual law on end-of-life care. Relying on scattered court rules just isn’t enough. Canada’s MAID model could help lawmakers here sketch out something solid and predictable.⁴⁶ 

Policymakers have a role, too. They should make sure that Advance Medical Directives—living wills—get tied into digital health systems like the Ayushman Bharat Health Account. That way, doctors in an emergency can easily see what a patient wants. People’s preferences won’t get buried in paperwork or lost in the shuffle. 

Medical training needs to catch up. Universities should bring in courses on end-of-life care, ethics, and how to talk honestly and gently with patients and families. The goal should be to get everyone on the medical team thinking together, so families don’t end up with mixed messages. 

Finally, society itself needs to have this conversation. People need to know what Advance Medical Directives are—and why they matter. If more people make informed decisions ahead of time, it can ease both the emotional and financial strain on families when crises hit. 

In the end, the Harish Rana case is about making the law serve people—not just by preserving life, but by protecting dignity. With this ruling, the Supreme Court makes it clear: life and death aren’t opposites when it comes to dignity—they’re connected. Now, India’s legal system has to keep building on that idea, making sure people are cared for, respected, and allowed to make their own choices right to the very end. 

Footnote(S):

[1]:INDIACONST. art.21. 

[2]:SeeFrancisCoralieMullinv.UnionTerritoryofDelhi,(1981)1S.C.C.608(holdingthatthe righttolife includesthe righttolivewithhumandignityandall thatgoes alongwithit). 

[3]:GianKaurv.StateofPunjab,(1996)2S.C.C.648. 

[4]:ArunaRamchandraShanbaugv.UnionofIndia,(2011)4S.C.C.454. 

[5]:CommonCause (ARegd.Society)v.UnionofIndia,(2018)5S.C.C.1. 

[6]:See alsoCommonCausev.UnionofIndia,(2023)5S.C.C.341(simplifyingtheproceduralguidelinesforthe enforcementofAdvanceMedical Directives). 

[7]:INDIACONST. art.21. 

[8]:IndianPenalCode,1860,§309. 

[9]:P.Rathinamv.UnionofIndia,(1994)3S.C.C.394. 

[10]:GianKaurv.StateofPunjab,(1996)2S.C.C.648. 

[11]:ArunaRamchandraShanbaugv.UnionofIndia,(2011)4S.C.C.454. 

[12]:CommonCause (ARegd.Society)v.UnionofIndia,(2018)5S.C.C.1. 

[13]:SeeCommonCausev.UnionofIndia,(2023)5S.C.C.341(refiningandsimplifyingtheproceduralhurdlesfor executingAdvanceMedicalDirectives). [^14]:HarishRanav.UnionofIndia,(2026)SCCOnLineSC[XXX]. 

[15]:INDIACONST. art.21. 

[16]:SeeFrancisCoralieMullinv.UnionTerritoryofDelhi,(1981)1S.C.C.608(holdingthatthe righttolife includesthe righttolivewithhumandignity). [^17]:GianKaurv.StateofPunjab,(1996)2S.C.C.648. 

[18]:ArunaRamchandraShanbaugv.UnionofIndia,(2011)4S.C.C.454. 

[19]:CommonCause (ARegd.Society)v.UnionofIndia,(2018)5S.C.C.1. 

[20]:HarishRanav.UnionofIndia,(2026)SCCOnLineSC[XXX]. 

[21]:HarishRanav.UnionofIndia,(2026)SCCOnLineSC[XXX]. 

[22]:HarishRanav.UnionofIndia,2024SCCOnLineDel[XXX]. 

[23] C C (A d S i ) i f di (2018) SCC 1

[23]:CommonCause (ARegd.Society)v.UnionofIndia,(2018)5S.C.C.1. 

[24]:HarishRana,(2026)SCCOnLineSC[XXX]. 

[25]:CommonCause,(2018)5S.C.C.1. 

[26]:INDIACONST. art.21. 

[27]:HarishRana,(2026)SCCOnLineSC[XXX]. 

[28]:TerminationofLifeonRequest andAssistedSuicide (ReviewProcedures)Act(Apr.1,2002)(Neth.). 

[29]:Carterv.Canada (AttorneyGeneral),[2015]1S.C.R.331(Can.). 

[30]:SeeMedicalAssistance inDyingAct,S.C.2016, c.3(Can.);AnActtoamendtheCriminalCode (medical assistance indying),S.C.2021, c.2(Can.) (commonlyreferredtoasBillC-7). 

[31]:SCHWEIZERISCHESSTRAFGESETZBUCH[STGB][CRIMINALCODE]Dec.21,1937,SR311.0, art.115(Switz.). [^32]:HarishRanav.UnionofIndia,(2026)SCCOnLineSC[XXX]. 

[33]:Id. 

[34]:SeeMedicalCouncilofIndia,CodeofEthicsRegulations,2002. 

[35]:TheBharatiyaNyayaSanhita,2023,No.45,ActsofParliament,2023(India). 

[36]:The IndianPenalCode,1860,§§306,309. 

[37]:TheMentalHealthcareAct,2017,§115. 

[38]:HarishRana,(2026)SCCOnLineSC[XXX]. 

[39]:INDIACONST. art.21. 

[40]:HarishRana,(2026)SCCOnLineSC[XXX]. 

[41]:TheRightsofPersonswithDisabilitiesAct,2016,No.49,ActsofParliament,2016(India). 

[42]:ConventionontheRightsofPersonswithDisabilities,Dec.13,2006,2515U.N.T.S.3. 

[43]:SeeCommonCause (ARegd.Society)v.UnionofIndia,(2018)5S.C.C.1. 

[44]:NationalHealthAuthority,AyushmanBharatDigitalMission(ABDM),https://healthid.ndhm.gov.in/(lastvisitedMay2,2026). [^45]:INDIACONST. art.21. 

[46]:SeeMedicalAssistance inDyingAct,S.C.2016, c.3(Can.).

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