Article 21 of theConstitution of India is a provision inPart III (Fundamental Rights) that guarantees the protection of life and personal liberty. The exact text reads: "No person shall be deprived of his life or personal liberty except according to procedure established by law."[1]
The scope of Article 21 has been expansively interpreted by theSupreme Court of India through a series of landmark judgments, transforming the clause from a narrow guarantee against physical deprivation to a comprehensive right encompassing dignity and certain procedural safeguards. The Constitution Bench decision inManeka Gandhi v. Union of India (1978) held that the "procedure established by law" must be "fair, just and reasonable", effectively reading a due-process component into Article 21 and linking it with other fundamental rights.[2]
Judicial developments followingManeka Gandhi recognized that Article 21 protects not only the right to life in the narrow sense (i.e., protection from arbitrary deprivation of life) but also facets of life essential to human dignity. The Supreme Court has held that the right to livelihood, the right to privacy in certain contexts, the right to a clean environment, and the right to medical care and health fall within the ambit of Article 21. Landmark rulings exemplifying these expansions includeKharak Singh v. State of Uttar Pradesh (1962) on domiciliary visits and surveillance,Francis Coralie Mullin v. Administrator, Union Territory of Delhi (1981) on detention and humane treatment, andOlga Tellis v. Bombay Municipal Corporation (1985) on the right to livelihood.[3][4][5]