Supreme Court Authorises Withdrawal of Life Support in First Judicial Application of Passive Euthanasia Guidelines
The Supreme Court of India on Wednesday permitted the withdrawal of life support for a man who has remained in a permanent vegetative state for more than thirteen years. The order marks the first judicial implementation of the passive euthanasia framework laid down in the Constitution Bench decision in Common Cause v. Union of India, which recognised the fundamental right to die with dignity. The Court later modified those guidelines in 2023.
A Bench of Justice J. B. Pardiwala and Justice K. V. Viswanathan passed the order while deciding a miscellaneous application filed by the father of Harish Rana. The application sought permission to withdraw all life-sustaining treatment administered to his son.
Medical Condition of the Patient
Harish Rana, aged 32, has remained in an irreversible persistent vegetative state for the last thirteen years after falling from the fourth floor of his paying guest accommodation.
While recording the facts of the case, the Bench observed:
“Harish Rana, presently aged 32 years, was once a young, bright boy. He met with a tragic life-altering accident after a fall from the fourth floor of his paying guest accommodation. His brain injury left him in a condition of Persistent Vegetative State (PSV) with 100% quadraplegia… Medical reports show that his medical condition has not improved in the past 13 years.”
Medical records before the Court showed that the patient survives only through Clinically Administered Nutrition (CAN). Doctors supply this nutrition through surgically installed PEG tubes.
The Court clarified that CAN qualifies as medical treatment. Therefore, doctors may withdraw it if the Primary Medical Board and Secondary Medical Board determine that continuing treatment is not in the patient’s best interest.
Findings of Medical Boards
The Court examined the reports of both medical boards. These reports indicated that Rana’s condition had not improved in thirteen years.
The Bench observed that the ongoing treatment only prolonged his biological existence. It offered no therapeutic improvement.
The Court also noted that Rana’s parents and both medical boards agreed on one conclusion. They believed that continuing CAN was not in the patient’s best interests and that doctors should discontinue the treatment.
Court’s Observations on Passive Euthanasia Procedure
The Bench clarified an important aspect of the passive euthanasia guidelines laid down in the Common Cause case.
Once the Primary Medical Board and Secondary Medical Board unanimously certify that life support should be withdrawn, courts generally do not need to intervene. However, the present matter reached the Court because this is the first case in which the guidelines have been implemented.
The Court emphasised that authorities must withdraw life support in a dignified manner.
Directions Issued by the Supreme Court
The Court directed that doctors withdraw or withhold all medical treatment administered to the patient, including Clinically Administered Nutrition. It also waived the reconsideration period of thirty days.
The Bench further directed the All India Institute of Medical Sciences (AIIMS) to admit the patient to its palliative care centre so that the withdrawal of CAN can take place under medical supervision. AIIMS must also facilitate the transfer of the patient from his residence to the palliative care centre.
The Court emphasised that doctors must implement the withdrawal of life support through a carefully designed plan that preserves the patient’s dignity.
In addition, the Court directed High Courts across all States to instruct Judicial Magistrates to receive hospital intimations whenever Primary and Secondary Medical Boards unanimously decide to withdraw or withhold life support under the Common Cause guidelines.
The Bench also directed the Union of India to ensure that Chief Medical Officers in all districts maintain panels of Registered Medical Practitioners who can serve on Secondary Medical Boards.
The Court further recommended that the Union Government consider introducing comprehensive legislation governing passive euthanasia.
Opinions of the Bench
Justice Pardiwala authored the main judgment. Justice Viswanathan delivered a concurring opinion.
The Bench also recorded its appreciation for the parents of Harish Rana. The Court acknowledged their dedication and care for their son during the prolonged period of illness.
Justice Pardiwala observed:
“His family never left his side…to love someone is to care for them even in the darkest times.”
Legal Framework: Common Cause Judgment
In the Constitution Bench decision in Common Cause v. Union of India, the Supreme Court recognised the right to die with dignity as part of Article 21 of the Constitution.
The Court also created procedural safeguards for passive euthanasia. It required approval from both a Primary Medical Board and a Secondary Medical Board before doctors could withdraw life support.
The Supreme Court modified these guidelines in January 2023.
The present matter is the first case in which courts have implemented these guidelines through a judicial order.
Background of the Case
The petitioner, through his father, first approached the Delhi High Court in 2024 seeking permission for passive euthanasia. In July 2024, the High Court dismissed the petition. It observed that the patient was not terminally ill.
The petitioner then moved the Supreme Court of India. In August 2024, the Court declined to entertain the plea. However, it directed the State of Uttar Pradesh to bear the treatment expenses.
In 2025, the petitioner filed a miscellaneous application in the disposed matter. The application stated that the patient’s condition had worsened and that there was no possibility of recovery. The Court then directed the constitution of a Primary Medical Board.
The Primary Medical Board concluded that the chances of recovery were negligible. The report stated that the patient remained bedridden with a tracheostomy tube for respiration and a gastrostomy tube for feeding. Photographs placed before the Court also showed severe bed sores.
The Court subsequently directed the All India Institute of Medical Sciences to constitute a Secondary Medical Board. After reviewing its report, Justice Pardiwala described the findings as a “sad report” and remarked that the patient could not continue living in such circumstances.
Before passing the final order, the Bench also met the patient’s parents.
Representation
Advocate Rashmi Nandkumar appeared for the petitioner.
Aishwarya Bhati, Additional Solicitor General, represented the Union of India.
Case Details:
Harish Rana v. Union of India
MA 2238/2025 in SLP(C) No. 18225/2024
