"No person shall be deprived of his life or personal liberty except according to the procedure established by law".

Article 21 of the Indian Constitution guarantees the fundamental right to life and personal liberty to every individual. It is one of the most crucial and widely interpreted provisions in Indian jurisprudence. This article not only protects the physical existence of citizens but also encompasses a broader understanding of life, including dignity, privacy, and basic human rights. Over the years, Article 21 has evolved through judicial interpretation to encompass various aspects such as environmental protection, right to education, healthcare, and a fair trial, making it a cornerstone of India's constitutional framework.

Background Context
During British rule, India faced significant challenges related to civil liberties and human rights. The colonial administration often used arbitrary detention, censorship, and repressive measures to suppress dissent and control the population. Indian freedom fighters and leaders, such as Mahatma Gandhi, Jawaharlal Nehru, and Dr. B.R. Ambedkar, emphasized the importance of individual rights and freedoms in a democratic society.

After India gained independence in 1947, the Constituent Assembly was tasked with drafting the Constitution. The debates in the Constituent Assembly reflected diverse viewpoints on the scope and nature of fundamental rights. Several members, including Dr. B.R. Ambedkar, emphasized the need to protect fundamental rights as essential pillars of democracy. The debates also highlighted the influence of international human rights principles and legal frameworks on the drafting of India's Constitution.

The framers of the Indian Constitution recognized the importance of enshrining fundamental rights to safeguard individual liberties and prevent abuse of state power. The Fundamental Rights chapter, including Article 21, was inspired by the Universal Declaration of Human Rights and other international treaties. Article 21 was specifically included to guarantee the right to life and personal liberty, reflecting the values of justice, equality, and dignity.

Since its enactment, Article 21 has undergone significant interpretation and evolution through judicial pronouncements. The Supreme Court of India has expanded the scope of Article 21 to include a wide range of rights, such as the right to privacy, right to health, right to clean environment, right to livelihood, and right to education.

Article 21 has had a profound impact on Indian society by empowering individuals to challenge arbitrary state action, seek justice, and assert their rights. It has served as a safeguard against human rights violations, ensuring accountability and transparency in governance. The ongoing interpretation and enforcement of Article 21 continue to shape India's legal framework and contribute to the protection of fundamental freedoms.

Expansion of the Article 21 of the Indian Constitution by adding the following rights in Right to Life:

1. Right to Privacy The Indian Constitution's Article 21 right to privacy has generated a great deal of judicial interpretation and legal discussion. The Supreme Court of India rendered a number of historic rulings that explicitly recognized the right to privacy as a fundamental right under Article 21. In the landmark 2017 decision of K.S. Puttaswamy v. Union of India, (2017), also referred to as the Aadhaar verdict, the Supreme Court upheld the fundamental principle that privacy is a necessary component of the right to life and personal liberty protected by Article 21.
   
   The Supreme Court's decision in the Puttaswamy case emphasized that privacy is essential for safeguarding individual autonomy, dignity, and personal choices. It recognized privacy as a core value that underpins other fundamental rights, such as freedom of speech, expression, and association. The right to privacy under Article 21 encompasses various facets, including informational privacy, bodily integrity, spatial privacy, and decisional autonomy.
   
   It protects individuals from unwarranted intrusion by the state or private entities into their private lives, communications, personal data, and bodily autonomy. While affirming the right to privacy, the Supreme Court has also recognized that the state may impose reasonable restrictions on privacy rights in the interest of national security, public order, morality, and other legitimate concerns. The Supreme Court's pronouncements on privacy rights under Article 21 have set important precedents for future cases involving privacy violations. Subsequent judgments have built upon the Puttaswamy case, refining the understanding of privacy in various contexts, including surveillance, social media, healthcare, and reproductive rights.
   
   The right to privacy under Article 21 of the Indian Constitution is a vital aspect of individual freedom and dignity. Its recognition and protection by the judiciary have contributed to shaping India's legal landscape and ensuring that privacy rights are upheld in the face of evolving societal challenges and technological advancement.
    
2. Right to Live with Human Dignity Judge P.N. Bhagwati broadened the meaning of the right to life under Article 21 of the Indian Constitution in Bandhua Mukti Morcha v. Union of India (1983), stating that it includes the right to live with human dignity. He underlined that this right encompasses the requirements for a dignified existence in addition to basic survival. Judge Bhagwati connected this more expansive reading to Articles 39(e) and (f), 41, and 42 of the Directive Principles of State Policy.
   
   These clauses compel the state to guarantee the right to work, education, and support in the event of a disability, as well as to safeguard decent working conditions and the health and well-being of workers and children.
   
   He emphasized that the state should be guided by the right to dignity, which is based on these ideas. This judgment thus bridged fundamental rights with socio-economic welfare goals, underscoring the state's role in promoting social justice and human dignity.
   
   
3. Right to Travel Article 21 has been an ever-developing law in itself. The rise of this development began in 1978, when Maneka Gandhi brought a case against the passport issuing authorities, who denied giving access without disclosing any reasonable grounds, stating that such non-disclosure was in the general public's interest.
   
   In this case, the primary opinion of the bench was that impounding was null and void as there was no reasonable opportunity given to the petitioner to be heard in her defense. The case proved the catalytic agent that formed various judicial opinions on Article 21. The concept of personal liberty was given the broadest amplitude that covers those rights that, in one way or another, constitute a person's liberty.
   
   Depriving an applicant of the right to know why the application was rejected harmed their liberty. It was here that Justice Krishnan Iyer stated that the right to travel abroad falls under the ambit of Article 21.
   
   
4. Right to a Fair and Speedy Trial The Indian Supreme Court addressed the issue of long-term incarceration of convicts awaiting trial in Hussainara Khatoon v. Home Secretary, State of Bihar (1979), highlighting the right to personal liberty guaranteed by Article 21 of the Indian Constitution. The case brought to light the fact that many people were detained for protracted periods of time while awaiting trial and without a conviction.
   
   The court ruled that detaining someone without a trial for an extended period of time is a serious violation of their right to personal liberty, and that a prompt trial is a crucial component of that right. It further underlined that the state's responsibility is to guarantee that the accused receive a speedy and fair trial. The ruling stressed that undertrial inmates must not be kept in jail without charge or trial and demanded quick changes to the criminal justice system to stop such delays.
   
   Thus, Hussainara Khatoon reinforced that the right to personal liberty includes not only protection against wrongful conviction but also protection against unnecessary and prolonged pre-trial detention. It established that procedural fairness and the right to a speedy trial are integral to the constitutional guarantee of personal liberty under Article 21.
   
    
5. Right to bail and free legal aid The Supreme Court of India emphasized the significance of equity in the bail-granting procedure in Babu Singh v. State of Uttar Pradesh (1978), since it directly affects the right to personal liberty guaranteed by Article 21 of the Constitution. The Court noted that denying bail and placing severe or unfair conditions on it violates the accused person's fundamental rights.
   
   Bail requirements shouldn't be applied to guarantee an extended stay of imprisonment or to erect an unfair roadblock in the way of the accused's release from custody. The ruling emphasized that the terms of bail must not be punitive in character and must be reasonable, considering the facts of the case.
   
   The Court also stressed that a person's socioeconomic background shouldn't be a barrier to accessing the legal system. A prisoner's right to legal help cannot be withheld just because they are impoverished or unable to pay for legal counsel. According to Article 21, the right to a fair trial is a fundamental component of personal liberty, and having access to legal assistance is necessary to guarantee that justice is not withheld because of financial difficulties.
   
   It is the responsibility of the state to help those who cannot afford legal representation, so that every citizen, regardless of financial situation, has an equal chance to defend themselves. Thus, Babu Singh reinforced that the right to bail and legal aid are integral to ensuring personal liberty and access to justice under Article 21. Both rights protect individuals from arbitrary detention and ensure that justice is administered fairly, irrespective of their economic status.
    
6. Right against solitary confinement The Sunil Batra cases have been a landmark concerning the right against solitary confinement as enshrined under Article 21. In Sunil Batra I (1975), the accused was awarded solitary confinement not because of disciplinary action but because he was to get the death penalty. He pleaded this to be against Article 21, as prisoners have a right to move and mingle unless the same is to be curtailed for specific reasons. Similarly, reasonable treatment in prison was violated when Sunil Batra II (1979) took place, where a letter intimating the torture of a fellow prisoner by the prison warden was sent to the authorities.
    
7. Right to education In Unnikrishnan v. State of Andhra Pradesh (1993), the Supreme Court of India recognized the right to education as a fundamental right under Article 21, which guarantees the right to life and personal liberty. The Court held that the right to education is essential for the full development of an individual, particularly in a child's formative years. In its judgment, the Court emphasized that free and compulsory education for children up to the age of 14 is crucial for improving the standard of living of people and promoting social and economic development.
   
   The rationale behind the age limit of 14 years is based on the developmental needs of a child. Primary education is seen as a foundation that equips children with the basic skills and knowledge necessary for their overall growth and their ability to contribute to society. The Court linked this right to education with the Directive Principles of State Policy, particularly Article 45, which called for free and compulsory education for children up to 14 years. By recognizing this right, the Court aimed to address illiteracy and improve opportunities for the marginalized sections of society.
   
   This decision laid the groundwork for the introduction of Article 21A in the Constitution through the 86th Amendment in 2002, making free and compulsory education for children aged 6 to 14 a fundamental right. It acknowledged education as a key factor in enhancing individual dignity and enabling citizens to participate meaningfully in the democratic process. Thus, Unnikrishnan was a landmark case that underscored the role of education in ensuring the holistic development of children and enhancing the overall well-being of society.
   
   
8. Right to shelter and livelihood In Chameli Singh v. State of Uttar Pradesh (1995), it was brought to light that the right to life guaranteed under Article 21 guarantees, in any civilised society, the right to food, water, decent environment, education, medical care and shelter. Here, shelter includes an adequate living space in a safe and decent structure with clean surroundings, air, light, water, electricity and sanitation, along with other civic amenities.
    
9. Right to sleep Every age group is accorded a minimum number of hours of sleep, which is important to improve their quality of life, brain activity and mood. Sleep not only ensures that your body has adequate energy but, interestingly, de-stresses the heart, helps improve metabolism and produces hormones that promote alertness in the mind. Besides, not getting enough sleep may lead to problems that may affect one's capacity to think clearly.
   
   This ratio was also taken into account by the Madhya Pradesh High Court in the matter of Sayeed Maqsood Ali v. State of Madhya Pradesh (2001), wherein it stated that every citizen is entitled to live in a decent environment and the right to have a peaceful night's sleep.
   
   Ramlila Maidan v. Home Secretary, Union of India (2011) Suo moto action was taken against the brutal actions of police against those sleeping in Ramleela Maidan, which was given on rent for a yoga training camp organised by Baba Ramdev. Four days into the campaign, Baba Ramdev started a hunger strike against corruption with a mass crowd of over 50,000 people. Considering that the strike was not called off, people involved in the strike were sleeping in that area in unity. At midnight, around 12 a.m., the police started the lathi charge and used tear gas to remove the crowd. Many lives were lost, and people suffered with burns and injuries.
   
   A two-judge bench stated this to be a violation of not only the right to assemble peacefully and without arms, along with the freedom to speech and expression, but also the right to sleep as per Article 21.
    
10. Noise pollution and the right to sleep The effect of noise pollution on an individual's sleep, including that of a foetus, was discussed in the case of Re: Noise Pollution (2005), where the right to sleep, the freedom to not listen, and the right to remain silent were discussed.
    
    The fact that people are not able to sleep due to the rise in pollution levels can result in a great deal of inconvenience and discomfort for people, including adverse health effects. Therefore, the Supreme Court prohibited using a trumpet or any sound amplifier at night between 10:00 p.m. and 6:00 a.m., except in public emergencies.

Conclusion
The evolution of Article 21 of the Indian Constitution showcases its dynamic and ever-expanding nature in safeguarding fundamental rights. Originally meant to protect the right to life and personal liberty, Article 21 has been interpreted by the judiciary to include a wide range of essential rights crucial for ensuring human dignity. The Supreme Court's role in expanding its scope through landmark judgments has been instrumental in shaping the legal landscape of India.

Through these judicial interpretations, the meaning of "life" has moved beyond mere physical survival to include the right to live with dignity, privacy, access to healthcare, education, and a clean environment.

For example, the recognition of the right to privacy in K.S. Puttaswamy v. Union of India (2017), and the right to education in Unnikrishnan v. State of Andhra Pradesh (1993) demonstrates the Court's progressive approach in understanding the social and economic needs of society. This approach is also reflected in judgments protecting marginalized sections, such as bonded labourers, underlining the state's duty to ensure socio-economic welfare.

Moreover, the interpretation of Article 21 to include the right to legal aid, fair bail conditions, and a speedy trial ensures that personal liberty is not unjustly curtailed, especially for vulnerable and marginalized individuals. The recognition of rights related to sleep, travel, and environmental protection further highlights the Court's endeavour to align Article 21 with the evolving needs of individuals in modern society.

The expansive interpretation of Article 21 demonstrates that the judiciary has successfully adapted this constitutional provision to address contemporary issues and challenges. By linking it with the Directive Principles of State Policy, courts have promoted social justice, ensuring that the rights of individuals are protected in a more holistic and inclusive manner. Thus, the ongoing evolution of Article 21 continues to reinforce its significance as the cornerstone of individual freedoms in India's constitutional framework.

Award Winning Article Is Written By: Mr.Abhishek Kumar

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