Facts
The applicant, Harish Rana, suffered a severe traumatic brain injury in 2013.
Source reference: p.6, para. 6He has remained in a Persistent Vegetative State (PVS) for over 12 years, suffering from 100% permanent physical disability and quadriplegia.
Source reference: p.8, para. 11-12He is sustained via Clinically Assisted Nutrition and Hydration (CANH) through a surgically placed Percutaneous Endoscopic Gastrostomy (PEG) tube and a tracheostomy.
Source reference: p.7, para. 8The Delhi High Court previously dismissed a writ petition for the withdrawal of treatment, holding he was not "mechanically" kept alive.
Source reference: p.5, para. 3Upon moving the Supreme Court, the Court directed the constitution of Primary and Secondary Medical Boards.
Source reference: p.9-10, para. 13-15Both boards confirmed the condition is irreversible, curative treatment is futile, and the applicant exhibits no awareness.
Source reference: p.10-11, para. 14-16The parents and siblings requested the withdrawal of life support to allow a dignified death.
Source reference: p.13, para. 20Issues
Whether the administration of Clinically Assisted Nutrition and Hydration (CANH) is to be regarded as "medical treatment".
Source reference: p.110, para. 113What are the meaning, scope, and contours of the principle of "best interest of the patient" in Determining withdrawal of treatment.
Source reference: p.110, para. 113Whether it is in the best interest of the applicant that his life be prolonged by continuation of medical treatment.
Source reference: p.110, para. 113What further steps and procedural streamlining are required for implementing the withdrawal of treatment.
Source reference: p.110, para. 113Law Applied
The court primarily applied Article 21 of the Constitution of India, interpreting the "right to live with dignity" to include the "right to die with dignity".
Source reference: p.39, para. 47; p.42, para. 52The court relied extensively on *Common Cause v. Union of India (2018)* and *(2023)*, which legalized passive euthanasia (withdrawal of life support) and established procedural guidelines.
Source reference: p.25, para. 29-30It also adopted the "Best Interest Principle" and "Substituted Judgment Standard" as discussed in *Airedale NHS Trust v. Bland*.
Source reference: p.158, para. 158The UK *Mental Capacity Act, 2005* was also referenced.
Source reference: p.168, para. 172The court clarified that CANH is "medical treatment" rather than basic care, citing *In re Conroy* and *Re BWV*.
Source reference: p.117, para. 119; p.124, para. 126Reasoning
The Court reasoned that CANH requires clinical indicators, surgical intervention (PEG tube), and medical monitoring for complications, thus qualifying as "medical treatment" amenable to withdrawal.
Source reference: p.114-116, para. 116-117Applying the "Best Interest Principle," the Court found that for a patient in a PVS with no hope of recovery, the continuation of treatment is "medically futile" and offers no benefit, merely prolonging biological existence in a state of indignity.
Source reference: p.163, para. 163; p.235, para. 239The Court utilized a "balance sheet approach," weighing medical futility and the "substituted judgment" of the family (reflecting what the patient would have wanted) against the presumption of life.
Source reference: p.228, para. 231-232Since the medical boards were unanimous regarding irreversibility and the family concurred that the patient’s former energetic personality would not have consented to such a state, the Court concluded that the burdens of treatment far outweighed any benefits.
Source reference: p.235, para. 239Holding
The Court answered the issues by declaring that CANH is indeed medical treatment and its withdrawal is in the applicant's best interest.
The Court allowed the application and directed the withdrawal/withholding of CANH.
Source reference: p.282, para. 327(a)AIIMS must admit the applicant to its Palliative Care department to implement withdrawal under a structured palliative and End-of-Life (EOL) care plan.
Source reference: p.282, para. 327(c-d)The 30-day "reconsideration period" was waived due to stakeholder unanimity.
Source reference: p.282, para. 327(b)Chief Medical Officers (CMOs) nationwide must maintain panels of doctors for Secondary Medical Boards to prevent administrative delays.
Source reference: p.283, para. 327(f)The Court urged the Union Government to enact comprehensive legislation on end-of-life care.
Source reference: p.280, para. 323Original Court PDF
Harish Rana v. Union of India & Ors. [2026 INSC 222 (Miscellaneous Application No. 2238 of 2025 in SLP (C) No. 18225 of 2024)]
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