Harish Rana v. Union of India has clarified the legal position on withdrawal of life-sustaining treatment in cases involving patients in a permanent vegetative state. The Hon’ble Supreme Court of India permitted withdrawal of life support for a patient who had remained in a permanent vegetative state for more than thirteen years, thereby allowing passive euthanasia in accordance with the constitutional right to die with dignity.
The case arose from a tragic accident in 2013 when Harish Rana, a young student, fell from a fourth-floor building and suffered catastrophic brain injuries, leaving him in a permanent vegetative state with complete quadriplegia. Since the accident, he had been sustained only through Clinically Assisted Nutrition and Hydration administered through surgically installed PEG tubes, with no possibility of neurological recovery.
After remaining in such condition for over thirteen years, the patient’s family approached the courts seeking permission to withdraw life-sustaining treatment. The matter ultimately reached the Hon’ble Supreme Court of India after the plea was earlier declined by the Hon’ble High Court.
The Hon’ble Supreme Court examined the medical reports submitted by the medical boards as well as the legal principles laid down in Common Cause v. Union of India, which recognised the right to die with dignity as part of Article 21 of the Constitution of India.
The Hon’ble Court made the following directions:
The medical treatment, including the CAN administered to the patient, shall be withdrawn or withheld. The reconsideration period of 30 days was waived. AIIMS shall grant admission to the patient to its palliative care centre, so that the withdrawal of CAN can be given effect to. AIIMS shall give all facilities for shifting the applicant from residence to the palliative care centre.
It must be ensured that life support is withdrawn with a tailored plan so that dignity is maintained.
The Hon’ble High Courts of all States shall issue directions to all Judicial Magistrates to receive intimations from hospitals, in accordance with the guidelines laid down in Common Cause in the event the Primary Medical Board and Secondary Medical Board arrive at a unanimous decision to withdraw or withhold life support.
Union of India shall ensure that Chief Medical Officers in all districts maintain a panel of Registered Medical Practitioners for nomination to the secondary medical boards.
Considering the unanimous opinion of the medical boards and the wishes expressed by the patient’s family, the Hon’ble Supreme Court permitted withdrawal of life-sustaining treatment and directed that appropriate palliative care measures be provided to ensure dignity and comfort to the patient.
The judgment marks an important application of the constitutional principle recognising the right to die with dignity and reiterates that withdrawal of life-sustaining treatment may be permitted in appropriate cases in accordance with established medical and legal safeguards.
