The term ‘life’, as used in Article 21, means something more than a mere animal existence. Elucidate.

Article 21 of the Constitution protects the life and personal liberty of every person. Earlier, the term ‘life’ was literally interpreted by the Court but later this term was liberally interpreted including everything which is essential for a dignified life. 

Justice Subba Rao in Kharak Singh v. State of Uttar Pradesh, 1964 SCR (1) 332 quoted from Justice Field in Munn v. Illinois, 94 U.S. 113 (1876) to emphasize the quality of life covered by Article 21 as under-

By the term “life,” as here used, something more is meant than mere animal existence.

The inhibition against its deprivation extends to all those limbs and faculties by which life is enjoyed. The provision equally prohibits the mutilation of the body by the amputation of an arm or leg, or the putting out of an eye, or the destruction of any other organ of the body through which the soul communicates with the outer world.

Further, in Munn v. Illinois, 94 U.S. 113 (1876) the court observed that by the term “liberty,” as used in the provision, something more is meant than mere freedom from physical restraint or the bounds of a prison. It means freedom to go where one may choose, and to act in such manner, not inconsistent with the equal rights of others, as his judgment may dictate for the promotion of his happiness that is, to pursue such callings and avocations as may be most suitable to develop his capacities and give to them their highest enjoyment.

In Boiling v. Sharpe, (1954) 347 U.S. 407, 499 the Supreme Court of America observed that the said expression was not confined to mere freedom from bodily restraint and that liberty under law extended to the full range of conduct which the individual was free to pursue.

Supreme Court in Kharak Singh v. State of Uttar Pradesh, defined the right of personal liberty in Article 21 as a right of an individual to be free from restrictions or encroachments on his person, whether those restrictions or encroachments are directly imposed or indirectly brought about by calculated measures.

The right to life is undoubtedly the most fundamental of all rights. All other rights add quality to the life in question and depend on the pre-existence of life itself for their operation. As human rights can only attach to living beings, one might expect the right to life itself to be in some sense primary, since none of the other rights would have any value or utility without it. There would have been no Fundamental Rights worth mentioning if Article 21 had been interpreted in its original sense.

The apex Court, in the case of Chameli Singh & others v. State of Uttar Pradesh and another, MR 1996 SC 1051, held as follows:

Right to life” means to live like a human being and it is not ensured by meeting only the animal needs of man. It includes the right to live in any civilised society implies the right to food, water, decent environment, education, medical care and shelter.

The Supreme Court has reiterated in many cases its stand that right to life was something more than mere animal existence.