The Supreme Court on Wednesday (March 11, 2026) practically applied the principles of passive euthanasia for the first time by permitting the withdrawal of clinically-assisted nutrition and hydration (CANH) to 32-year-old Harish Rana.

A Bench of Justices JB Pardiwala and K.V. Viswanathan said withdrawal of life support must neither be a “single act” nor an “act of abandonment” of patients in persistent vegetative state (PVS). 

The court laid down that withdrawal of life support must be in the “best interests” of the patient and guiding factors include whether life support provided to the patient qualify as medical treatment; whether medicines have any therapeutic benefit, but only works to prolong life, pain and suffering for the patient; and whether it would be in the best interest of the patient to artificially prolong life.

The process of withdrawal of CANH must be part of a well-structured, tailored, robust and articulated palliative care plan for a patients in his or her most vulnerable phase of life.

Firmly appending the withdrawal of life support to palliative care, the court said the patient must be looked after in a sensitive manner with concerns for his or her dignity given foremost importance.

The judgment decisively draws the boundaries on when to allow natural death to take over.

The judgment came after the Bench conducted long, measured and multi-tiered consultations with Mr. Rana’s family, medical boards and counsel appearing for both the family members and the Centre. A team led by Additional Solicitor General Aishwarya Bhati had visited the Rana residence and submitted an eyewitness report to the Supreme Court

The Bench had personally met Mr. Rana’s parents and siblings, who said they did not want him to suffer anymore.

The court had also recorded the submission made by Ms. Bhati that primary and secondary boards of doctors who visited Mr. Rana was also of the opinion that medical treatment should be discontinued and “nature should be allowed to take its own course”.

Mr. Rana had sustained severe head injuries and 100% quadriplegic disability after sustaining a fall from the fourth floor of his paying guest accommodation as a Panjab University student in 2013. He has been bed-ridden for over 13 years now.

“The doctors are of the opinion that Harish would remain in this permanent vegetative state (PVS) for years to come... He would never be able to recover and live a normal life,” the apex court had recounted in the January 15 order.

The hearings in the case had seen the Rana family lawyer, advocate Rashmi Nandakumar, urge the court to not use the terminology ‘passive euthanasia’ and instead use ‘withdrawing/withholding life-sustaining treatment’ in its judgment. Justice Pardiwala had said the thought was in the minds of the judges from the very first day.

The hearings had delved into the emotional weight of decisions in such cases with Justice Viswanathan, at one point, asking what would happen if a distressed family changed their mind to not go ahead in conflict with the medical opinion. Justice Pardiwala had at the time pointed out that the medical board may not come into the picture until and unless the family’s consent to withdrawing life support was made in writing.

The hearing had highlighted the importance of the family taking a “consistent and well-considered” decision. Ms. Nandakumar had also submitted that hospitals ought to nominate doctors who would be part of medical boards assigned to undertake the medical examinations in cases in which family members have come forward with a wish to withdraw life support.

In 2018, a Constitution Bench of the apex court had upheld passive euthanasia and the right to give advance medical directives or ‘Living Wills’ to smoothen the dying process as part of the fundamental right to live with dignity. The court had ruled that the fundamental right to life and dignity under Article 21 of the Constitution included the “right to die with dignity”.

However, active euthanasia is illegal in India due to apprehensions of misuse unlike Canada’s Medical Assistance in Dying programme (MAiD). Former Canadian diplomat David Malone had reportedly chosen the option in November last year after being diagnosed with early Alzheimer’s.

One of the first indications of judicial application of mind to passive euthanasia could be found in the 1996 Gian Kaur verdict. Though the Supreme Court in that case had dealt with the legality of penalising attempt to die by suicide, it gave an “indication” that passive euthanasia would only “accelerate the process of dying” in the case of terminally-ill persons or patients in persistent vegetative state.

In 2011, the apex court was met with the tragic case of the bed-ridden former Mumbai nurse Aruna Shanbaug and admitted to initially “feeling like a ship in uncharted sea”. It refused euthanasia for Ms. Shanbaug, who had been bed-ridden for over four decades due to injuries sustained in a sexual assault on her. However, the apex court laid down procedural guidelines for passive euthanasia in its judgment. Ms. Shanbaug died four years later, in May 2015. The staff at Mumbai’s KEM Hospital had taken care of her till her natural death.

In 2018, a five-judge Constitution Bench in the Common Cause case decided to lend more clarity by upholding the legality of passive euthanasia and concept of ‘Living Will’ - an advance written directive to physicians for end-of-life medical care.

The court observed that dignity was lost if a person was allowed or forced to undergo pain and suffering because of “unwarranted medical support” despite being in a persistent vegetative state.

The judgment legalised passive euthanasia despite the government’s arguments that it was drafting a legislation called ‘The Management of Patients With Terminal Illness – Withdrawal of Medical Life Support Bill’, which was drawn up in line with the recommendations of the Law Commission of India that life support can be withdrawn for patients in persistent vegetative state (PVS) or suffering an irreversible medical condition.

“The right of a dying person to die with dignity when life is ebbing out, and in the case of a terminally ill patient or a person in permanent vegetative state, where there is no hope of recovery, accelerating the process of death for reducing the period of suffering constitutes a right to live with dignity,” Chief Justice of India Dipak Misra (now retired) had observed in the lead opinion.

In his separate opinion, Justice D.Y. Chandrachud (now retired) had observed that “to deprive a person dignity at the end of life is to deprive him of a meaningful existence”.