Report No. 210
Right to live: Ambit and scope - It is settled law that life does not mean 'animal existence'. Before more than 100 years, it was recognized by the U.S. Supreme Court in the leading case of Munn v. Illinois, (1876) 94 US 113. This principle is recognized by our Supreme Court in Kharak Singh AIR 1963 SC 1295, Sunil Batra v. Delhi Administration, AIR 1978 SC 1675, and in various other cases.
After Maneka Gandhi v. Union of India, AIR 1978 SC 597, various rights have been held to be covered by Article 21; such as right to go abroad, right to privacy, right against solitary confinement, right to speedy trial, right to shelter, right to breathe in unpolluted environment, right to medical aid, right to education, etc. Thus, life does not mean mere living, but a glowing vitality - the feeling of wholeness with a capacity for continuous intellectual and spiritual growth.