## Facts

- Aruna Ramachandra Shanbaug, a nurse at KEM Hospital in Mumbai, was violently assaulted in 1973, causing severe brain damage from strangulation.
- She remained hospitalized for decades in a persistent vegetative state, dependent on caregivers for feeding and basic nursing care.
- A journalist-author, acting as “next friend,” filed an Article 32 petition seeking permission to withdraw nutrition and medical support (passive euthanasia).
- The court appointed an amicus curiae and constituted a medical board to examine Shanbaug and report on her condition.
- The medical board reported she was not brain-dead, showed some reflex responses, and was sustained primarily by oral feeding and nursing care rather than extraordinary life-support machinery.
- KEM Hospital staff who had cared for Shanbaug opposed withdrawal of feeding and sought continuation of care.

## Issues

1. Whether Article 21’s right to life includes a right to die or a right to die with dignity in end-of-life situations.
2. Whether passive euthanasia (withholding/withdrawing life-sustaining treatment) is legally permissible, and under what conditions.
3. Who may seek or authorize withdrawal of life support for a person in a persistent vegetative state, and what safeguards are required.
4. Whether withdrawal of nutrition and support should be permitted on the facts of Shanbaug’s case.

## Decision

- The court denied permission to withdraw feeding and care in Shanbaug’s case.
- It held that the hospital staff, given their longstanding caregiving relationship, were the more appropriate “next friends” and their opposition to euthanasia carried decisive weight on the facts.
- It reaffirmed that active euthanasia (a deliberate act to cause death) is unlawful under existing criminal law absent legislative authorization.
- It allowed passive euthanasia in principle in exceptional cases, but only through a judicially supervised process.
- It issued interim guidelines to govern passive euthanasia until enacted legislation, directing that prior approval be sought from the jurisdictional High Court.

## Legal Principles

- Active euthanasia (affirmative steps intended to cause death) is treated as criminal homicide under existing law and is impermissible without legislative change.
- Passive euthanasia (withholding or withdrawing life-prolonging measures) may be lawful in limited circumstances if authorized through strict judicial safeguards.
- Article 21 does not recognize a generalized “right to die,” but permits consideration of a dignified dying process in narrowly defined end-of-life contexts.
- Decisions to withdraw life support for an incompetent patient must be made under judicial oversight using a “best interests” standard, not solely private choice.
- Procedural safeguards for passive euthanasia require: a High Court petition (by close relatives, a genuine next friend, or the hospital), notice to the State and interested parties, an independent medical board report, and a reasoned judicial determination.

## Conclusion

The court refused to allow withdrawal of feeding and care for Shanbaug, while establishing that passive euthanasia may be permitted in exceptional cases only with prior High Court approval, independent medical assessment, notice and hearing, and a best-interests determination; active euthanasia remained prohibited under existing criminal law.


Aruna Ramachandra Shanbaug v. Union of India, (2011) 4 S.C.C. 454 (India)