Abstract
A major advancement in India's end-of-life jurisprudence under Article 21 of the Constitution was made by the Supreme Court's ruling in Harish Rana v. Union of India, 2026 SCC OnLine SC 358. The case involved a patient who was dependent on Clinically Assisted Nutrition and Hydration (CANH) given via a Percutaneous Endoscopic Gastrostomy (PEG) tube and had been in a Permanent Vegetative State for thirteen years after suffering a serious, permanent neurological lesion. The Court's main concern was whether CANH qualified as medical therapy that may be legally discontinued in accordance with the rules allowing passive euthanasia. According to the Supreme Court, CANH delivered via a PEG tube is considered medical therapy and may be legally discontinued, subject to the relevant safeguards, if it has proven ineffective and only prolongs biological existence. The Court also emphasized that decisions about stopping life-sustaining treatment must be made with the patient's best interests in mind, taking into account medical prognosis, the likelihood of recovery, therapeutic benefit, dignity, treatment burden, family opinions, and medical ethics. The Court also reaffirmed the constitutional recognition of the right to die with dignity under Article 21. Additionally, the ruling simplified and clarified the Common Cause v. Union of India procedural framework, especially with regard to medical boards, end-of-life decisions, and judicial intervention. Crucially, the Court emphasized that proper palliative and end-of-life care must continue and that stopping ineffective treatment does not equate to abandoning. The judgment significantly aided in the creation of a cohesive medico-legal framework in India by highlighting the necessity of comprehensive laws covering advance medical directives, passive euthanasia, and end-of-life care.