Article 21 And Its Ever Expanding Scope
The right to live a free, full and dignified life is one of the most basic
principles of human existence. Every person is entitled to live their life on
their own terms, with no unfair interference from others. A successful democracy
can only be one that guarantees its citizens the right to protect their own life
and liberty. In India, the Protection of Life and Personal Liberty is a
Fundamental Right granted to citizens under Part III of the Constitution of
India, 1950.
These Fundamental Rights represent the foundational values cherished by the people and are granted against actions of the state, meaning that no act of any state authority can violate any such right of a citizen except according to the procedure established by law.[1] Often characterized as 'the procedural Magna Carta protective of life and liberty, Article 21, in our living Constitution, is the most organic and progressive provision.
Embodying the 'constitutional value of supreme importance in a democratic society, Article 21[2] of the Indian Constitution, 1950 provides, "No person shall be deprived of his life or personal liberty except according to procedure established by law." Interpreted as "the heart of the constitution", this article offers three keywords with ever-expanding definitions- life, personal liberty, and state
"Life" under Article 21, has been defined as more than just the act of breathing.[3]
A.K Gopalan v. State of Madras[6]
This case is also known as the Preventive Detention case. It is a landmark case in Indian Constitution law deal with the interpretation of key fundamental rights under Article 19 and 21 of the Indian Constitution. As it established a precedent for the protection of individuals' rights under Preventive Detention laws. This was the first case after independence of India.[7]The Hon'ble Supreme Court held that the protection of Article 21 is available only against the executive action. But legislative may deprive a person by making a law.[8]
Kharak Singh v. State of U.P. and Ors. (1964)[9]
It was held that the right to personal liberty constitutes not only the right to be free from restrictions placed on one's movements but also to be free from encroachments on one's private life. Thus, personal liberty was considered to include all the residual freedoms of a person not included in Article 19(1).
Maneka Gandhi vs. UOI, 1978[10]
In this case, Hon'ble Supreme Court held that the protection of Article 21 is available not only against executive action but also against legislative. In simple words, the legislature cannot deprive a person of the right to life and personal liberty even by making a law.
The right to life does not mean only animal existence. Under this article, right to life means all the aspects of life which make human life dignified.
Earlier, Articles 19 and 21 were held to be completely exclusive and separate from each other. The position changed slowly as Personal Liberty evolved to include all rights other than those mentioned in Article 19, and they were considered complementary to each other.
The present case, however, brought a sea change. The Supreme Court held that Articles 19(1)[11] and 21 are not mutually exclusive as the Right to Life and Personal Liberty covers a wide variety of rights, some of which have been given additional protection under Article 19(1).
Article 19 and Article 21 go hand-in-hand and the procedure established by law restricting these rights should stand the scrutiny of other provisions of the Constitution as well – including Article 14.[12] Thus, a law encroaching upon one's personal liberty must not only pass the test of Article 21 but also of Article 14 and Article 19 of the Constitution.
These three rights are, hence, interconnected and provide safeguards against arbitrary actions of the government. They are meant to be read together and interpreted in accordance with each other. All three of them grant basic human rights and freedoms to the citizens and their immense collective importance has given them the name "Golden Triangle" in jurisprudence.[13]
Sunil Batra v. Delhi Administration (1978)[14]
In this case, the Supreme Court held that fatal cuffs are unconstitutional for a convicted person because it is an inhuman behaviour with the prisoners, and it is a violation of Article 21.
Hussainara Khatoon and Ors. v. Home Secretary, State of Bihar (1979)[15]: Right to Speedy Trial for Under trials
The Supreme Court held that though the right to a speedy trial is not specifically listed as a Fundamental Right in the Indian Constitution, it is implicit in the broad scope of Article 21. Speedy trial is the essence of criminal justice and hence, no procedure which does not ensure a reasonably quick trial could be "reasonable, fair or just." Thus, the Bihar Government was ordered to start the trials of the prisoners as soon as possible.
Prem Shankar Shukla v. Delhi Administration(1980)[16]: Handcuffing as a prima facie violation of Article 21
The Court held that handcuffs are prima facie inhuman, unreasonable, and at first blush arbitrary without fair procedure and objective monitoring and a prima facie violation of one's right to life and personal liberty enshrined under Article 21. The Court recognized the need to secure the prisoner from fleeing but asserted that this does not compulsorily require handcuffing.[17]
Bachan Singh v. State of Punjab(1980)[18]: Death Penalty
The court upheld the constitutional validity of the death penalty saying that it did not violate Articles 14, 19 and 21, but reiterated that it could only be awarded in the "rarest of rare" cases, and not as a substitute for life imprisonment. Thus, while capital punishment is a very harsh punishment, it is essential in the grossest and most serious cases like the murder of several persons, a brutal rape, etc. to properly administer justice and act as a deterrent in society. Its constitutional validity has been upheld by the Supreme Court. However, a high burden must be placed on the judge to duly consider and be satisfied with the awarding of a death sentence.[19]
Olga Tellis and Ors. v. Bombay Municipal Corporation (1986)[20]: Right to Livelihood
The Court held that the right to life, in Article 21 of the Constitution, encompassed means of livelihood since, if there is an obligation upon the State to secure to citizens an adequate means of livelihood and the right to work, it would be sheer pedantry to exclude the right to livelihood from the content of the right to life.[21]
Neeraja Chaudhary v. State of M.P. (1984)[22]: Right of the Bonded labourers to a dignified life
The court emphasized upon the need for proper rehabilitation of the labourers to uphold their Right to Life and Personal Liberty granted by Article 21 and ordered the State government to undertake appropriate measures for the same.
Attorney General of India v. Lachma Devi and Ors. (1985)[23]: Public Hanging violative of Article 21.
The case of Attorney General of India v/s Lachma Devi 1985, dealt with the controversial issue of the right to public hanging in India. The case was brought to the Supreme Court of India to determine whether the public hanging of a convicted murderer could be considered a violation of their fundamental rights.[24]The bench condemned public hanging as being unconstitutional and grossly violative of Article 21 of the Constitution, thus deleting that previous order of the High Court.Thus, while a death sentence remains a method of punishment in the most serious crimes, it need not be taken to the extent of a public hanging to further humiliate the convict and cause turmoil in society.
Rural Litigation and Entitlement Kendra v. State of U.P. (1985)[25] or the Dehradun Valley Litigation: Right to Healthy Environment
The court only allowed a few mines to remain open while all the others, which were causing harm, were shut down. The Valley was declared as an ecologically sensitive area and measures were taken for its restoration. Most importantly, this case led to the enactment of the Environment Protection Act, 1986.[26]It was held that "The Constitution of India guarantees the privilege of a healthy environment as a fundamental right under Article 21.
Industrialization leads to evolution which additionally leads to the deprivation of the environment. The theory of sustainable development has developed over the years that there must be a balance between evolution and ecology. Environmental dishonoring is not right on the pretext of national benefit. According to the socio-economic desires of the nation, administrative and legislative policies for compatible environmental and evolution principles should be intimated."[27]
M.C. Mehta and Anr. v. Union of India (1987)[28] or the Shriram Food and Fertilizer Case
This judgement, after the deadly Bhopal Gas Disaster in 1984, changed the scope, extent, and application of not only the environmental laws in India but also that of Article 21 dealing with the right to life and personal liberty and Article 32 dealing with remedies for violations of fundamental rights of the Constitution of India.[29] It established the principle of absolute liability, which involves holding the industry dealing in hazardous substances absolutely liable for all damages caused by its faulty operations.
Pt. Parmanand Katara v. Union of India (1989)[30]: Right to health and assistance
It was recognised that Article 21 renders paramount importance to the preservation of human life. Thus, it is the obligation of all medical professionals to give immediate health assistance to all patients, without being put under any legal impediment. It was decided that no medical professional shall be harassed for any investigation and he or she would not be asked to testify in court unless necessary and absolutely relevant. Thus, this case freed the medical professionals of any legal restrictions and thereby made it an obligation and duty for them to provide immediate assistance to patients to uphold the Right to Life.
Subhash Kumar v. State of Bihar (1991)[31]: Right to clean environment
The court confirmed that the Fundamental Right to Life includes the right to enjoy pollution-free water and air, and if anything endangers the quality of water and air then a citizen can file a petition in court.
Mohini Jain vs. the State of Karnataka( 1992)[32]: Right to education
The Supreme Court held that although the right to education as such has not been guaranteed as a fundamental right under the Constitution, it becomes clear from the Preamble of the Constitution and its Directive Principles, contained in section IV, that the framers of the Constitution intended the State to provide education for its citizens. The court links the right to education to the right to life by reasoning that to sustain life a human being requires the fulfilment of all the enabling rights which create life of dignity. The court also held that accessibility to education should be realized for all people, rich or poor.[33]
P. Rathinam v. Union of India (1994)[34]: Right to Die
Keeping Article 21 as well as the principles of natural justice in mind, the two-judge bench ruled that Right to Life also included the right to not live a forced life. Therefore, Section 309 of the Indian Penal Code was declared void.
Vishaka and Ors. v. State of Rajasthan and Ors. (1997)[35]: Right against Sexual Harassment
The apex court held that Sexual Harassment violates the fundamental right of the women of gender equality which is codified under Article 14 of Indian Constitution and also the fundamental right to life and to live a dignified life is violated/infringed under Article 21 of constitution of India.[36]
Re-Ramlila Maidan Incident v. Home Secretary and Ors. (2012)[37]: Right to sleep
The court acknowledged that sleep is an essential part of a healthy life and a necessity for the maintenance of individual peace. Thus, it held that every person is entitled to sleep as comfortably and freely as he breathes. If any person's sleep is disturbed without any reasonable justification, it amounts to torture and is a violation of his human rights. Therefore, making the sleeping persons flee and causing mayhem at the location was held as unlawful, since there was no illegal activity taking place there.
Justice K.S. Puttaswamy (Retd.) v. Union of India (2017)[38]: Right to Privacy
The Supreme Court held that a fundamental right to privacy is guaranteed under the Article 21 Constitution of India.[39]
Conclusion:
The Right to Life and Personal Liberty has a wide ambit which is only growing over time. There has been increasing awareness about the various aspects of a person's life which he or she is entitled to control and which would, thus, facilitate the enhancement in quality of his or her life. This Right has been described as the "heart and soul" of the Constitution of India by the Supreme Court and certainly proves to be so – representing the very basic necessities of human life.
End-Notes:
These Fundamental Rights represent the foundational values cherished by the people and are granted against actions of the state, meaning that no act of any state authority can violate any such right of a citizen except according to the procedure established by law.[1] Often characterized as 'the procedural Magna Carta protective of life and liberty, Article 21, in our living Constitution, is the most organic and progressive provision.
Embodying the 'constitutional value of supreme importance in a democratic society, Article 21[2] of the Indian Constitution, 1950 provides, "No person shall be deprived of his life or personal liberty except according to procedure established by law." Interpreted as "the heart of the constitution", this article offers three keywords with ever-expanding definitions- life, personal liberty, and state
"Life" under Article 21, has been defined as more than just the act of breathing.[3]
Scope of Article 21
The scope of Article 21 was limited[4] until the 1950s, with the Supreme Court ruling in A.K. Gopalan v. State of Madras[5] that segregated the contents and subject matter of Article 21 and 19 (1) (d) as "non-identical, proceeding on different principles".A.K Gopalan v. State of Madras[6]
This case is also known as the Preventive Detention case. It is a landmark case in Indian Constitution law deal with the interpretation of key fundamental rights under Article 19 and 21 of the Indian Constitution. As it established a precedent for the protection of individuals' rights under Preventive Detention laws. This was the first case after independence of India.[7]The Hon'ble Supreme Court held that the protection of Article 21 is available only against the executive action. But legislative may deprive a person by making a law.[8]
Kharak Singh v. State of U.P. and Ors. (1964)[9]
It was held that the right to personal liberty constitutes not only the right to be free from restrictions placed on one's movements but also to be free from encroachments on one's private life. Thus, personal liberty was considered to include all the residual freedoms of a person not included in Article 19(1).
Maneka Gandhi vs. UOI, 1978[10]
In this case, Hon'ble Supreme Court held that the protection of Article 21 is available not only against executive action but also against legislative. In simple words, the legislature cannot deprive a person of the right to life and personal liberty even by making a law.
The right to life does not mean only animal existence. Under this article, right to life means all the aspects of life which make human life dignified.
Earlier, Articles 19 and 21 were held to be completely exclusive and separate from each other. The position changed slowly as Personal Liberty evolved to include all rights other than those mentioned in Article 19, and they were considered complementary to each other.
The present case, however, brought a sea change. The Supreme Court held that Articles 19(1)[11] and 21 are not mutually exclusive as the Right to Life and Personal Liberty covers a wide variety of rights, some of which have been given additional protection under Article 19(1).
Article 19 and Article 21 go hand-in-hand and the procedure established by law restricting these rights should stand the scrutiny of other provisions of the Constitution as well – including Article 14.[12] Thus, a law encroaching upon one's personal liberty must not only pass the test of Article 21 but also of Article 14 and Article 19 of the Constitution.
These three rights are, hence, interconnected and provide safeguards against arbitrary actions of the government. They are meant to be read together and interpreted in accordance with each other. All three of them grant basic human rights and freedoms to the citizens and their immense collective importance has given them the name "Golden Triangle" in jurisprudence.[13]
Sunil Batra v. Delhi Administration (1978)[14]
In this case, the Supreme Court held that fatal cuffs are unconstitutional for a convicted person because it is an inhuman behaviour with the prisoners, and it is a violation of Article 21.
Hussainara Khatoon and Ors. v. Home Secretary, State of Bihar (1979)[15]: Right to Speedy Trial for Under trials
The Supreme Court held that though the right to a speedy trial is not specifically listed as a Fundamental Right in the Indian Constitution, it is implicit in the broad scope of Article 21. Speedy trial is the essence of criminal justice and hence, no procedure which does not ensure a reasonably quick trial could be "reasonable, fair or just." Thus, the Bihar Government was ordered to start the trials of the prisoners as soon as possible.
Prem Shankar Shukla v. Delhi Administration(1980)[16]: Handcuffing as a prima facie violation of Article 21
The Court held that handcuffs are prima facie inhuman, unreasonable, and at first blush arbitrary without fair procedure and objective monitoring and a prima facie violation of one's right to life and personal liberty enshrined under Article 21. The Court recognized the need to secure the prisoner from fleeing but asserted that this does not compulsorily require handcuffing.[17]
Bachan Singh v. State of Punjab(1980)[18]: Death Penalty
The court upheld the constitutional validity of the death penalty saying that it did not violate Articles 14, 19 and 21, but reiterated that it could only be awarded in the "rarest of rare" cases, and not as a substitute for life imprisonment. Thus, while capital punishment is a very harsh punishment, it is essential in the grossest and most serious cases like the murder of several persons, a brutal rape, etc. to properly administer justice and act as a deterrent in society. Its constitutional validity has been upheld by the Supreme Court. However, a high burden must be placed on the judge to duly consider and be satisfied with the awarding of a death sentence.[19]
Olga Tellis and Ors. v. Bombay Municipal Corporation (1986)[20]: Right to Livelihood
The Court held that the right to life, in Article 21 of the Constitution, encompassed means of livelihood since, if there is an obligation upon the State to secure to citizens an adequate means of livelihood and the right to work, it would be sheer pedantry to exclude the right to livelihood from the content of the right to life.[21]
Neeraja Chaudhary v. State of M.P. (1984)[22]: Right of the Bonded labourers to a dignified life
The court emphasized upon the need for proper rehabilitation of the labourers to uphold their Right to Life and Personal Liberty granted by Article 21 and ordered the State government to undertake appropriate measures for the same.
Attorney General of India v. Lachma Devi and Ors. (1985)[23]: Public Hanging violative of Article 21.
The case of Attorney General of India v/s Lachma Devi 1985, dealt with the controversial issue of the right to public hanging in India. The case was brought to the Supreme Court of India to determine whether the public hanging of a convicted murderer could be considered a violation of their fundamental rights.[24]The bench condemned public hanging as being unconstitutional and grossly violative of Article 21 of the Constitution, thus deleting that previous order of the High Court.Thus, while a death sentence remains a method of punishment in the most serious crimes, it need not be taken to the extent of a public hanging to further humiliate the convict and cause turmoil in society.
Rural Litigation and Entitlement Kendra v. State of U.P. (1985)[25] or the Dehradun Valley Litigation: Right to Healthy Environment
The court only allowed a few mines to remain open while all the others, which were causing harm, were shut down. The Valley was declared as an ecologically sensitive area and measures were taken for its restoration. Most importantly, this case led to the enactment of the Environment Protection Act, 1986.[26]It was held that "The Constitution of India guarantees the privilege of a healthy environment as a fundamental right under Article 21.
Industrialization leads to evolution which additionally leads to the deprivation of the environment. The theory of sustainable development has developed over the years that there must be a balance between evolution and ecology. Environmental dishonoring is not right on the pretext of national benefit. According to the socio-economic desires of the nation, administrative and legislative policies for compatible environmental and evolution principles should be intimated."[27]
M.C. Mehta and Anr. v. Union of India (1987)[28] or the Shriram Food and Fertilizer Case
This judgement, after the deadly Bhopal Gas Disaster in 1984, changed the scope, extent, and application of not only the environmental laws in India but also that of Article 21 dealing with the right to life and personal liberty and Article 32 dealing with remedies for violations of fundamental rights of the Constitution of India.[29] It established the principle of absolute liability, which involves holding the industry dealing in hazardous substances absolutely liable for all damages caused by its faulty operations.
Pt. Parmanand Katara v. Union of India (1989)[30]: Right to health and assistance
It was recognised that Article 21 renders paramount importance to the preservation of human life. Thus, it is the obligation of all medical professionals to give immediate health assistance to all patients, without being put under any legal impediment. It was decided that no medical professional shall be harassed for any investigation and he or she would not be asked to testify in court unless necessary and absolutely relevant. Thus, this case freed the medical professionals of any legal restrictions and thereby made it an obligation and duty for them to provide immediate assistance to patients to uphold the Right to Life.
Subhash Kumar v. State of Bihar (1991)[31]: Right to clean environment
The court confirmed that the Fundamental Right to Life includes the right to enjoy pollution-free water and air, and if anything endangers the quality of water and air then a citizen can file a petition in court.
Mohini Jain vs. the State of Karnataka( 1992)[32]: Right to education
The Supreme Court held that although the right to education as such has not been guaranteed as a fundamental right under the Constitution, it becomes clear from the Preamble of the Constitution and its Directive Principles, contained in section IV, that the framers of the Constitution intended the State to provide education for its citizens. The court links the right to education to the right to life by reasoning that to sustain life a human being requires the fulfilment of all the enabling rights which create life of dignity. The court also held that accessibility to education should be realized for all people, rich or poor.[33]
P. Rathinam v. Union of India (1994)[34]: Right to Die
Keeping Article 21 as well as the principles of natural justice in mind, the two-judge bench ruled that Right to Life also included the right to not live a forced life. Therefore, Section 309 of the Indian Penal Code was declared void.
Vishaka and Ors. v. State of Rajasthan and Ors. (1997)[35]: Right against Sexual Harassment
The apex court held that Sexual Harassment violates the fundamental right of the women of gender equality which is codified under Article 14 of Indian Constitution and also the fundamental right to life and to live a dignified life is violated/infringed under Article 21 of constitution of India.[36]
Re-Ramlila Maidan Incident v. Home Secretary and Ors. (2012)[37]: Right to sleep
The court acknowledged that sleep is an essential part of a healthy life and a necessity for the maintenance of individual peace. Thus, it held that every person is entitled to sleep as comfortably and freely as he breathes. If any person's sleep is disturbed without any reasonable justification, it amounts to torture and is a violation of his human rights. Therefore, making the sleeping persons flee and causing mayhem at the location was held as unlawful, since there was no illegal activity taking place there.
Justice K.S. Puttaswamy (Retd.) v. Union of India (2017)[38]: Right to Privacy
The Supreme Court held that a fundamental right to privacy is guaranteed under the Article 21 Constitution of India.[39]
Conclusion:
The Right to Life and Personal Liberty has a wide ambit which is only growing over time. There has been increasing awareness about the various aspects of a person's life which he or she is entitled to control and which would, thus, facilitate the enhancement in quality of his or her life. This Right has been described as the "heart and soul" of the Constitution of India by the Supreme Court and certainly proves to be so – representing the very basic necessities of human life.
End-Notes:
- Jessica Kaur, Article 21: Meaning & Scope of Protection of Life & Personal Liberty, IPLEADERS (Jan. 12, 2024, 01:30 PM), https://blog.ipleaders.in/article-21/ .
- India Const. art. 21.
- Ashish Dash, The fundamentality of Fundamental rights in India: Right to health in the pandemic, THE TIMES OF INDIA (Dec. 02, 2021, 12:41 PM), https://timesofindia.indiatimes.com/readersblog/dash-insights/the-fundamentality-of-fundamental-rights-in-india-right-to-health-in-the-pandemic-39345/ .
- Id.
- A.K. Gopalan v. State of Madras, AIR 1950 SC 27 (India).
- Id.
- Yashika Chourasia, Summarize case: A Landmark case in India legal history: A.K. Gopalan v/s State of Madras, LEGAL SERVICE INDIA (Jan. 12, 2024, 01:30 PM), https://www.legalserviceindia.com/legal/article-14014-summarize-case-a-landmark-case-in-india-legal-history-a-k-gopalan-v-s-state-of-madras.html .
- WRITING LAW, https://www.writinglaw.com/14-famous-cases-on-right-to-life-and-personal-liberty-article-21/ (last visited Jan. 12, 2024).
- Kharak Singh v. State of U.P. and Ors, 1963 AIR 1295 (India).
- Maneka Gandhi vs. UOI, AIR 1978 SC 597 (India).
- India Const. art. 19, cl. 1.
- India Const. art. 14.
- Jessica Kaur, Article 21: Meaning & Scope of Protection of Life & Personal Liberty, IPLEADERS (Jan. 12, 2024, 01:30 PM), https://blog.ipleaders.in/article-21/ .
- Sunil Batra v. Delhi Administration, 1978 AIR 1975 (India).
- Hussainara Khatoon and Ors. v. Home Secretary, State of Bihar, 1979 AIR 1369 (India).
- Prem Shankar Shukla v. Delhi Administration, 1980 AIR 1535 (India).
- Devyani Srivastava, Illegal Practice of Handcuffing Continues in India.
- Bachan Singh v. State of Punjab, (1982) 3 SCC 24 (India).
- Jessica Kaur, Article 21: Meaning & Scope of Protection of Life & Personal Liberty, IPLEADERS (Jan. 12, 2024, 01:30 PM), https://blog.ipleaders.in/article-21/ .
- Olga Tellis and Ors. v. Bombay Municipal Corporation, 1985 SCC (3) 545 (India).
- ESCR-NET, https://www.escr-net.org/caselaw/2006/olga-tellis-ors-v-bombay-municipal-council-1985-2-supp-scr-51 (last visited Jan. 12, 2024).
- Neeraja Chaudhary v. State of M.P., 1984 AIR 1099 (India).
- Attorney General of India v. Lachma Devi and Ors, (1985) 1 SCC 686 (India).
- LEGALVIDHYA, https://legalvidhiya.com/attorney-general-of-india-v-lachma-devi-1985-1-scc 686/ (last visited Jan. 12, 2024).
- Rural Litigation and Entitlement Kendra v. State of U.P., 1985 S.C. 652 (India).
- Environment Protection Act, 1986, No.29, Acts of Parliament, 1986 (India).
- LEXPEEPS, https://lexpeeps.in/rural-litigation-and-entitlement-kendra-others-v-state-of-uttar-pradesh/ (last visited Jan. 12, 2024).
- M.C. Mehta and Anr. v. Union of India, 1987 AIR 1086 (India).
- Ishani Samajpati, MC Mehta vs. Union of India (1986): case analysis, IPLEADERS (Jan. 12, 2024, 02:30 PM), https://blog.ipleaders.in/mc-mehta-vs-union-of-india-1986-case-analysis/ .
- Pt. Parmanand Katara v. Union of India, 1989 AIR 2039 (India).
- Subhash Kumar v. State of Bihar, 1991 AIR 420 (India).
- Mohini Jain vs. the State of Karnataka, 1992 AIR 1858 (India).
- ESCR-NET, https://www.escr-net.org/caselaw/2009/mohini-jain-v-state-karnataka-1992-air-1858 (last visited Jan. 12, 2024).
- P. Rathinam v. Union of India, 1994 AIR 1844 (India).
- Vishaka and Ors. v. State of Rajasthan and Ors., AIR 1997 SC 3011 (India).
- Simran, Case Analysis- Vishaka and others v/s State of Rajasthan, LEGAL SERVICE INDIA (Jan. 12, 2024, 3:30 PM), https://www.legalserviceindia.com/legal/article-374-case-analysis-vishaka-and-others-v-s-state-of-rajasthan.html .
- Re-Ramlila Maidan Incident v. Home Secretary and Ors, (2012) 5 SCC 1 (India).
- Justice K.S. Puttaswamy (Retd.) v. Union of India, AIR 2017 SC 4161 (India).
- Supreme Court Observer, https://www.scobserver.in/cases/puttaswamy-v-union-of-india-fundamental-right-to-privacy-case-background/ (last visited Jan. 12, ,2024).
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