CASE OVERVIEW
Name of Case: Harish Rana v. Union of India & Ors
Citation: 2026 SCC OnLine SC 358
Court: Supreme Court
Bench: Justice J.B. Pardiwala and Justice K.V. Viswanathan
Date of Judgement: 11th March 2026
Why the Case Matters: The case looks into the extent of Right to Die with Dignity in terms of Article 21 in the case of a person in Permanent Vegetative State (PVS). It also defines the legal position regarding Clinically Assisted Nutrition and Hydration (CANH) along with the best-interest principle with regard to withdrawal of life-sustaining treatment.
FACTS OF THE CASE
Harish Rana at the age of 20 years suffered a severe brain injury (diffuse axonal injury) following a fall from the fourth floor of his paying guest accommodation on 20th August 2013. Despite medical treatment, he remained in an irreversible Permanent Vegetative State (PVS) for approximately thirteen years. He was unable to communicate, recognise people or independently perform basic bodily functions and remained dependent upon medical care.
Ever since the incident, the applicant has been on tracheostomy, urinary catheter and CANH administered through the Percutaneous Endoscopic Gastrostomy (PEG) Tube. Medical evaluations revealed that his condition was beyond medical assistance and that no considerable neurological recovery was possible. The medical boards further determined that any further treatment would be pointless and that continuing with it would not be beneficial to him.
The parents of Harish, who looked after him for thirteen years, applied for lifting the life-sustaining treatment. Their application stated that they had taken the decision after extensive thinking and had not been forced into it from elsewhere. His siblings held the same opinion regarding the issue.
The proceedings before the Supreme Court followed an earlier round of litigation concerning Harish’s treatment. In 2024, his parents approached the Delhi High Court under Article 226 seeking withdrawal of life-sustaining treatment. The petition was dismissed on the ground that Harish was not dependent on mechanical ventilation. The resulting Special Leave Petition was disposed of by the Supreme Court in November 2024, with a direction for state-funded home care.
As Harish’s condition subsequently deteriorated, his parents filed the present Miscellaneous Application in 2025 seeking reconsideration of the treatment being provided to him. The Court during its proceedings directed for Harish's case to be considered by the Primary Medical Board and the Secondary Medical Board as per the judgement in the case of Common Cause v. Union of India, 2018 and guidelines modified in 2023. Both boards ultimately supported withdrawal of the treatment.
ISSUES
The principal issues before the Court were:
Whether CANH administered through a PEG tube constitutes “medical treatment” which may legally be withheld or withdrawn.
Whether continued administration of CANH was in Harish Rana’s best interests, considering his irreversible permanent vegetative state and the medical evidence concerning his prognosis.
Whether withdrawal of CANH would fall within the constitutionally recognised framework governing withholding or withdrawal of life-sustaining treatment, as distinguished from active euthanasia.
What safeguards and procedural directions should govern the withdrawal or withholding of such treatment, particularly in cases where treatment is provided in a home setting.
These questions required the Court to examine Article 21, the right to die with dignity, the Common Cause framework, and the role of medical boards and the patient’s next of kin in end-of-life decisions.
JUDGEMENT/RATIONALE
The Supreme Court has decided that the twin legal requirements for the discontinuation of treatment were essentially met. First, CANH had to be considered medical treatment and Second, keeping treatment unchanged would not be beneficial for Harish. The Court has taken into account the unanimous conclusion from Primary Medical Board and Secondary medical Boards and the approved decision of Harish’s parents or relatives.
The court explained that CANH cannot be treated merely as ordinary feedings because its administration involves medical intervention, clinical judgement and continuing medical supervision. Consequently, it could fall within the framework governing withdrawal of life-sustaining treatment.
The Court applied the principles established in Common Cause, recognising that the Right to Life under Article 21 includes the Right to Live and Die with Dignity. Withdrawal of futile medical treatment, where the prescribed safeguards are satisfied, allows the underlying medical condition to take its natural course and is distinct from an act intended to directly cause death.
The best-interest principle formed the core of the Court’s reasoning. The Court made decisions based on this as well as various medical evidence which proved the irreversibility of Harish’s medical condition. It was also determined by the Court that because Harish’s condition was irreversible and only the food and nutrition could not help him recover or make it possible for him to have any therapeutic benefit.
Accordingly, the Court directed that the medical treatment, including CANH be withdrawn and/or Withheld. It waived the usual 30-day reconsideration period because all relevant stakeholders were unanimous. AIIMS was directed to admit Harish to its Palliative Care Department and ensure that the withdrawal took place under a suitable palliative and end-of-life care plan, with his comfort and dignity protected.
Moreover, the Court directed AIIMS to provide appropriate palliative and end-of-life care ensuring that Harish’s comfort and dignity were maintained throughout the process. The Court stated that the guidelines were meant to be used temporarily and were not aimed at being new laws. Therefore, it urged the government to adopt new laws concerning end-of-life regulations.
REFERENCES
Harish Rana v. Union of India & Ors, 2026 SCC OnLine SC 358
Common Cause v. Union of India, (2018) 5 SCC 1
Common Cause v. Union of India, (2023) 14 SCC 131