Question

Passive euthanasia under certain circumstance is permissible was upheld in the case of:

• A. Aruna Ramachandra Shanbaug v. Union of India
• B. Gian Kaur v. State of Punjab
• C. State of Maharashtra v. Maruty Sripaty Dubal
• D. P. Rathinam v. Union of India

Answer 1

The Correct Option is A

The Correct Option is (A):Aruna Ramachandra Shanbaug v. Union of India

Answer 2

This question is about which specific case first allowed passive euthanasia, that is, the withdrawal of life support from a patient in specific circumstances, to be legally permissible in India.

1. Aruna Ramachandra Shanbaug v. Union of India (2011): this case concerned a nurse who had been in a persistent vegetative state for decades after a brutal assault. On a petition filed on her behalf, the Supreme Court held that passive euthanasia, meaning the withdrawal of life-sustaining treatment, could be permitted in limited circumstances, subject to the approval of the jurisdictional High Court following a laid-down procedure. This was the first case where the Supreme Court recognised the legality of passive euthanasia in India.
2. Gian Kaur v. State of Punjab (1996): this case held that the right to life under Article 21 does not include a right to die, and upheld the constitutional validity of Section 306 of the Indian Penal Code, which punishes abetment of suicide. It overruled the earlier position in P. Rathinam and left open, without deciding, whether a terminally ill or incurable patient might have a right to a more dignified process of dying, but it did not itself lay down the passive euthanasia framework.
3. State of Maharashtra v. Maruty Sripaty Dubal: this was a Bombay High Court decision from 1987 that struck down Section 309 of the Indian Penal Code, which criminalised attempted suicide, as an early precursor to the debate on a right to die. It concerned suicide, not euthanasia for a patient who cannot make or communicate that decision themselves.
4. P. Rathinam v. Union of India (1994): the Supreme Court in this case had also struck down Section 309 of the Indian Penal Code, reading a right to die into Article 21. This was later overruled by the Constitution Bench in Gian Kaur, and in any case it dealt with the right of a person to end their own life, not with a court permitting withdrawal of treatment for someone in a vegetative state.

Aruna Shanbaug is the specific case that dealt with, and permitted under conditions, passive euthanasia, while the other three cases concern the separate and earlier debate over the constitutionality of punishing attempted suicide.

So the correct answer is Aruna Ramachandra Shanbaug v. Union of India.