Human rights have always been the cornerstone of civilized existence. They are inalienable, universal, sacrosanct, and inviolable. They uphold the value of human life. The right to life is among these rights that is most fundamental. No one's life or personal freedom may be taken from them unless legal processes are followed, according to the right to life. The right to life and personal freedom is protected under Article 21 of the Indian Constitution. Life, liberty, and dignity are three of its key components.

The scope of Article 21 has evolved over time in response to increasing judicial activism and concern for human rights to encompass a number of additional components that contribute to the meaning and worth of human life. In this assignment, we can see the comparison of the right to life and personal liberty between India, the U.S. And Singapore, before comparison we can see what is right to life and personal liberty in each country.
 
The Right to life and Personal liberty In India
As stated in Article 21 Right to Life and Personal Liberty: No person shall be deprived of his life or personal liberty except in accordance with the process established by law. Everyone has access to this essential right, both citizens and visitors.1

Two rights are provided under Article 21:

• Right to life2
• Personal liberty is a right

One of the most crucial rights that the Constitution protects is the basic right outlined in Article 21.This right has been referred to as the heart of fundamental rights by the Supreme Court of India. It is specifically stated in the right that no one may be robbed of their life or freedom in any other way than in line with the legal system.

The implication is that this right only applies to the State. In this usage, the term "state" encompasses not just the government but also any government-related bodies like legislatures and municipal groups.A violation of Article 21 does not occur when a private individual violates the rights of another.

In this case, the victim would have two alternatives for redress: general law or Article 226. Beyond only having the capacity to survive, everyone has the right to life. Living a complete life with dignity and Constitution" 6 Journal of Advances in Management IT and Social Sciences 2 (2016).a purpose also falls under this category. The major goal of Article 21 is to make sure that the State only infringes on a person's right to life or liberty when doing so follows the established legal procedure.

The AK Gopalan Case3
Served as a reminder that the reach of Article 21 was very constrained before the 1950s. In this ruling, the SC found that the Constitution's usage of the phrase procedure established by law had personal liberty, not American-style due process, at its heart.

In the Maneka Gandhi v. Union of India case 4, which was decided in 1978, the Gopalan case ruling was reversed. The SC ruled that Articles 19 and 21 in this case are not watertight containers. Many rights, some of which are codified under Article 19, are included in the broad concept of personal liberty in Article 21, providing them with additional protection.

The court ruled that a statute that falls under Article 21 must also meet the criteria set out in Article 19. This implies that any legal process intended to revoke someone's right to life or liberty must not be arbitrary, unjust, or irrational.

Elements of the right to life and personal Liberty:

• Right to privacy
• Right to go abroad
• Right to shelter
• Right against solitary confinement
• Right to social justice and economic empowerment
• Right against handcuffing
• Right against delayed execution
• Right against public hanging
• Protection of cultural heritage
• Right to pollution-free water and air
• Right of every child to full development
• Right to health and medical aid
• Right to education
• Protection of under-trials
• Right to hearing
• Right to electricity

Right to Life and Personal Liberty In U.S.A:

The right to life and personal freedom are protected by the following amendments in the USA:

• American citizens were given protections under the Fourth Amendment in 1791 against unreasonable searches and seizures of their persons, houses, papers, and effects. It aimed to safeguard the people's right to personal liberty.

1. The right to life and personal freedom are protected by a number of provisions in the Fifth Amendment to the United States Constitution. It contains the Due Process Clause, which prohibits the taking of someone's life, liberty, or property, without due process of law. This implies that before someone's life or freedom may be taken away, they have a right to a fair judicial procedure.
2. The 14th Amendment Another important clause that guarantees the protection of individual rights, such as the right to life and personal freedom, is the Fourteenth Amendment. It contains the Equal Protection Clause, which forbids the government from depriving anybody under its control of the same legal protections.
3. The Eighth Amendment forbids the use of cruel or unusual punishment. With the help of this legislation, the government will no longer be able to punish people with the death penalty or lengthy jail terms.
4. First Amendment: The First Amendment safeguards fundamental liberties including freedom of expression, religion, and assembly, which are intimately tied to personal liberty even if it does not mention the right to life and personal liberty directly.
5. Fourth Amendment: The Fourth Amendment safeguards people against arbitrary law enforcement searches and seizures. For personal liberty, privacy protection is crucial.
6. Ninth Amendment: The Ninth Amendment underlines that the Constitution's enumeration of some rights should not be interpreted as undermining or negating other rights that the people have preserved. This means that the right to life and personal freedom, among others, are protected by the Constitution in addition to those that are expressly included in it.

Supreme Court rulings:
To defend individual rights, such as the right to life and personal liberty, the U.S. Supreme Court has interpreted and implemented these constitutional clauses over time. Decisions like Miranda v. Arizona 6 safeguard people's rights while dealing with police enforcement, and precedent-setting judgments like Roe v. Wade 7 acknowledged a woman's freedom to decide about her own personal liberty.

• One thing to keep in mind is that, in contrast to India, the US supports due process of law rather than procedure established by law. In the US, judges are more empowered to determine whether the method used to take away someone's life or liberty is legitimate as well as the legitimacy of the law that defines it. The Maneka Gandhi decision led to a shift in the Indian legal system's perspective in favor of due process of law.
   
• The Fifth and Fourteenth Amendments, in particular, provide significant protection for the right to life and personal liberty in the United States. Here are some significant court rulings pertaining to these rights:
  • Griswold v. Connecticut 8: While not directly addressing the right to life and personal liberty, this case established the right to privacy, which is closely connected to personal liberty. The Court struck down a Connecticut law that prohibited the use of contraceptives, finding that the Constitution protects an individual's right to make private decisions regarding their personal life.
  • Roe v. Wade 9: This landmark case established a woman's right to choose to have an abortion as a part of her right to privacy. The Court held that this right falls under the broader concept of personal liberty protected by the Fourteenth Amendment.
  • Planned Parenthood v. Casey 10: This case reaffirmed the central holding in Roe v. Wade while allowing some restrictions on abortion. It emphasized the importance of personal liberty and bodily autonomy.
     
• These decisions shed light on how the courts have developed and construed the rights to life and personal liberty over time in the United States. Keep in mind that new cases and interpretations may cause the legal system to change.
   
• There are Some elements of right to life and personal liberty in US, But they have not said impliedly but they mentioned explicitly in the amendments they are and these elements will be compared between India and Singapore at last.

Right to Life and Personal Liberty In Singapore

• In Singapore, like in many other democratic countries, the right to life and personal liberty is a basic component of human rights and the rule of law. In this discussion, we will examine Singapore's legal system as it relates to these rights, referencing pertinent court cases as necessary.
• The Constitution and several laws of Singapore guarantee everyone's right to life and personal freedom. In some circumstances, these rights may also be subject to reasonable limitations. Here, we'll go into the legal framework and relevant case law to show the breadth and bounds of these rights.
• The Constitution of Singapore, which serves as the cornerstone for the preservation of fundamental rights, including the right to life and personal liberty, is the highest law of the state. The Constitution's Articles 9 and 12 are principally responsible for regulating these rights.
• Article 9 (1) reads: "No person shall be deprived of his life or personal liberty save in accordance with law."11

Case Laws on the Right to Life and Personal Liberty:

• Re Tan Boon Chong 12 In this case, the accused was sentenced to death for drug trafficking, which raised questions about the right to life. The Court held that the death penalty was constitutional and not in violation of Article 9 of the Constitution. It emphasized that the Constitution permits the death penalty for certain offenses, provided it is carried out in accordance with the law. This landmark case established the principle that the right to life and personal liberty could not be deprived of arbitrarily. The court held that the executive's discretionary powers should be limited, and any detention should be based on reasonable suspicion. The case emphasized the importance of procedural safeguards in ensuring that the rights enshrined in the Constitution are upheld.

Other Factors Impacting Personal Liberty:

• Singapore's strict laws on public assembly and freedom of speech have implications for personal liberty. The government argues that these restrictions are essential to maintain public order, but critics contend that they limit free expression and assembly rights.

Comparison of Right to life and Personal Liberty Between India, U.S.A and Singapore

The right to life and the right to personal freedom are essential human rights that are upheld by several legal systems worldwide. I can compare a basic comparison of how these rights are protected and interpreted in India, the United States, and Singapore, along with a comparison of elements of the right to life and personal liberty.

Comparative Analysis:

• Scope of Rights: India, the U.S., and Singapore all protect the right to life and personal liberty, but the scope and interpretation of these rights differ. While India and the U.S. have broader interpretations that encompass various aspects of personal freedom, Singapore's approach is more restrictive and emphasizes the importance of legality.
• Restrictions: All three countries allow for restrictions on these rights but with varying degrees of scrutiny. India and the U.S. generally apply a higher standard of scrutiny, emphasizing the need for laws to be reasonable and just. Singapore focuses on legality, necessity, and proportionality when limiting these rights.
• Cultural Context: Cultural, social, and political factors also influence the interpretation and enforcement of these rights. For example, in the U.S., the right to personal liberty has been extended to include issues like abortion, which may not be the case in India or Singapore.

It's important to note that the interpretation and protection of these rights can evolve over time and may be influenced by cultural, social, and political factors. Additionally, these countries have their own legal systems and traditions, which can impact the way these rights are understood and applied.
Comparative analysis of some Elements of the Right to life and Personal Liberty between India
USA and Singapore:

1. Right to Education:
   In India - The Constitution of India recognizes the right to education as a basic freedom in India. A key piece of law known as the Right to Education Act of 2009 (RTE Act) guarantees free and mandatory education for kids between the ages of 6 and 14. This law requires private schools to set aside a specific number of seats for students from underprivileged groups.
   
   Due to economic and infrastructure inequities, access to high-quality education is still a problem in many regions of India, notwithstanding legislative requirements. Although enrollment rates have increased, there are still problems with dropout rates and educational quality.
   
   Quality varies widely between different states and regions. In some areas, the quality of education is a concern, and infrastructure deficiencies persist. In US - The United States does not have a federal right to education in its Constitution. Education is primarily a state and local matter.
   
   However, federal laws, such as the Elementary and Secondary Education Act (ESEA), which includes the No Child Left Behind Act and Every Student Succeeds Act, aim to promote educational equity and set certain standards for schools.
   
   Public education is available to all children in the United States, but the quality and funding of schools can vary greatly between districts. Access to quality education is often linked to the economic well-being of the community.The quality of education can vary significantly from state to state, and there are persistent achievement gaps based on factors like race and income.
   
   In Singapore -Education in Singapore is also recognized as a fundamental right, and it is a duty for parents to ensure that their children receive an education. The Singapore government plays a significant role in regulating and funding the education system.
   
   Singapore boasts high enrolment rates in schools, and the government provides significant financial support to ensure that children from all socio-economic backgrounds have access to quality education. Singapore is known for having a high-quality education system, consistently ranking at or near the top in international education assessments. Thecurriculum is highly standardized, and there is a strong emphasis on science, technology, engineering, and mathematics (STEM) subjects.
    
2. Right to Health:
   In India - According to Article 21 of the Indian Constitution, which protects the right to life and individual liberty, India recognizes the right to health as a basic right. The Indian government has a duty to guarantee that its people have access to quality healthcare. Public and private healthcare providers make to India's healthcare system. Because public healthcare systems are frequently overworked and underfunded, many people turn to private healthcare, which can be costly. Through programs like the National Health Mission (NHM) and the Ayushman Bharat program, which aims to provide health insurance to economically vulnerable families, India has made efforts to increase access to healthcare.
   
   In US - The United States does not have a legally protected right to health. However, a number of legislation and initiatives, including Medicaid, Medicare, and the Affordable Care Act (ACA), have been put in place to guarantee access to healthcare. Because the U.S. healthcare system is largely private and market-driven, access to healthcare services is frequently correlated with insurance and income. Despite having some of the most cutting-edge medical facilities and research in the world, inequities in healthcare access and cost continue to be a major problem. There is continuing discussion and argument over why there isn't universal healthcare.
   
   In Singapore - Although it is not expressly stated in its constitution, Singapore respects the right to health as a basic concept. The government is dedicated to providing its residents with high-quality healthcare at reasonable prices. Singapore has a distinctive healthcare system with a mix of public and private components. To ensure quality and affordability, the government heavily regulates the healthcare sector. The Central Provident Fund (CPF) system in Singapore helps citizens save for healthcare expenses, and the government provides subsidies for lower-income individuals and families. The Medisave, MediShield, and Medi fund schemes also contribute to healthcare affordability.
    
3. Right to shelter:
   In India -According to Article 21 of the Indian Constitution, which protects the right to life and personal freedom, India acknowledges the right to shelter as a basic right. According to how the courts have understood this, this includes the right to appropriate housing. The Pradhan Mantri Awas Yojana (PMAY) is one of several housing programs the Indian government has undertaken to offer low-incomepeople affordable homes. Despite these initiatives, India still has a serious housing shortage and homelessness is still an issue in many metropolitan areas.
   
   In US - The right to shelter is not expressly acknowledged as a constitutional right in the United States. However, a number of federal and state initiatives offer low-income and homeless people and families housing aid. A federal statute known as the McKinney-Vento Homeless Assistance Act offers financing and assistance to those who are homeless, including programs, transitional housing, and emergency shelters. Although there are several groups and government initiatives striving to solve the issue, there is no countrywide assurance that all individuals will have housing.
   
   In Singapore - Singapore's constitution does not expressly protect the right to shelter, although it places a high priority on both public housing and property. The majority of the population in Singapore has access to cheap public housing thanks in large part to the Housing and Development Board (HDB). Although there are fewer homeless people in Singapore than in many other nations, housing affordability is still a problem, particularly for those who are low-income and members of disadvantaged groups.
    
4. Right to Go abroad:
   In India - Article 21 of the Indian Constitution, which protects the rights to life and personal liberty, deems the freedom to travel abroad to be a basic right in India. However, in some situations, such as those involving national security, this privilege may be curtailed.Indian nationals must have a current passport and, frequently, a visa in order to go overseas.
   
   For various purposes, the government offers several sorts of visas, and the application procedure might change. India has the authority to impose travel restrictions or add someone to a "no-fly" list for a variety of reasons, such as security concerns or legal matters. Travel restrictions may also be put in place by the government in times of emergency like the COVID-19 pandemic.
   
   In US - Although it is not specifically addressed in the US Constitution, the right to travel abroad is nonetheless regarded as a basic freedom. The Fifth Amendment's Due Process Clause normally protects it. Travel outside the US requires a current US passport. Depending on the location and goal of the journey, different nations have different visa requirements.
   
   The US State Department outlines the conditions for entering and leaving each nation. In the event of an emergency or for reasons of national security, the US government may impose travel restrictions, such as travel bans to certain nations or regions. Foreign nationals' visa and admission requirements are also subject to change.
   
   In Singapore - Although the Constitution of Singapore does not specifically mention the freedom to travel abroad, it is routinely upheld. For the sake of public order, security, or health, the government may impose restrictions on travel. Singaporeans must have a current passport in order to go abroad. Visa requirements vary by destination and travel objective for admission into other nations. With numerous nations, Singapore has visa-free or visa-on-arrival agreements. In response to health concerns like disease outbreaks, the Singaporean government may impose travel limits or advise against travelling to specific nations or locations.
    
5. Right to Hearing:
   In India - Article 21 of the Indian Constitution, which protects the right to life and personal freedom, has a provision that ensures the right to a fair hearing. This covers the right to an expedited and fair trial. India has an adversarial judicial system in which the parties concerned argue their arguments in front of a judge who is impartial. Indigent and marginalized people who cannot afford legal counsel are provided with legal help by the Indian legal system. The majority of court proceedings in India are open to the public, promoting accountability in the legal system.
   
   In US - The Sixth Amendment to the United States Constitution, which also protects the right to a quick and public trial, ensures the right to a fair hearing in the country. The legal system The common law legal system in the United States employs an adversarial process in which all parties argue their arguments in front of an unbiased judge and jury. Trials are often public, and the media usually reports on court events. The United States provides the right to legal counsel, and in the event that a person cannot afford one, a public defender will be assigned to ensure a fair trial.
   
   In Singapore - Several parts of Singapore's Constitution, notably Article 9 which forbids the abridgement of a person's life or personal freedom without due process of law-protect the right to a fair hearing. The common law and civil law traditions are combined in Singapore's legal system.
    

It uses an adversarial style, although there are also certain aspects of inquisitorial processes. Singapore offers legal help to anyone who cannot afford to hire an attorney, however it may be less comprehensive than in some other countries. Singaporean courts occasionally hold trials in secret to safeguard confidential material or concerns about national security.

Conclusion
So that I conclude by saying the comparison of the right to life and personal liberty between India US and Singapore .One of the most important human rights is the right to life, which protects not only an individual's life and freedom but also other aspects of life that make living valuable, such as a livelihood, dignity, shelter, privacy, and health. It is not unassailable and may be limited in accordance with the legal process.

However, it has been affirmed by the courts that in addition to the method being lawful, it should also be fair and based on a valid and just legislation. In India, Article 21 ensures the right to life and to human dignity and has been broadly interpreted by our judicial system. Additionally, it is permitted by international law and is available in other nations. It has also generated debate on controversial topics like euthanasia and the death penalty. But in every argument, the right to life has prevailed.

References:
Primary Sources:

• The Constitution of India, 1950 (India)
• The Constitution Of Republic Of Singapore, 1965 (Singapore)

Secondary Sources Books Referred

• Constitution of India, V.N.Shukla, 13th Edition, 2021

Articles / Journals Referred

• Dr. Bhavana Sharma, "Judicial Interpretation on Right to Life and Personal Liberty Under Article 21 of Indian Constitution" 6 Journal of Advances in Management IT and Social Sciences 2 (2016).

Websites Referred

• https://www.careerlauncher.com/upsc/article-21/ (Visited on 11 October 2023)
• https://www.legalpedia.co.in/articlecontent/article-21-introduction.html (Visited on 11 October 2023)
• https://www.aclu.org/documents/bill-rights-us-constitution#:~:. (Visited on 11 October 2023)
• https://www.archives.gov/milestone-documents/14th-amendment (Visited on 11 October 2023)
• https://sso.agc.gov.sg/Act/CONS1963?ProvIds=pr9- (Visited on 12 October 2023)
• https://www.wikiwand.com/en/Article_9_of_the_Constitution_of_Singapore (Visited on 12 October 2023)

End-Notes:

1. Article -21 of Constitution of India
2. Dr. Bhavana Sharma, "Judicial Interpretation on Right to Life and Personal Liberty Under Article 21 of Indian
3. AIR 1950 SC 27
4. AIR 1978 SC 59717. Right to sleep
5. Right to Life and Personal Liberty In US Amendments Available At:
   https://www.aclu.org/documents/bill-rights-us-constitution ) visited on October 14 ,20237.
6. 384 U.S. 436 (1966)
7. 410 U.S. 113 (1973)
8. 381 U.S. 479 (1965)
9. 410 U.S. 113 (1973)
10. 505 U.S. 833 (1992)
11. Article 9(1) -Constitution of the Republic of Singapore
12. [2010] SGHC 2182. Chng Suan Tze v. Minister for Home Affairs
13. (1988) SGCA 16