Held: The Supreme Court held that clinically assisted nutrition and hydration administered through a PEG tube constitutes life-sustaining medical treatment and may be withdrawn in an appropriate case in accordance with the principles laid down in Common Cause v. Union of India. The Court held that where a patient has remained in an irreversible permanent vegetative state for over thirteen years, with no chance of neurological recovery, and both the primary and secondary medical boards concur that continued treatment is futile and serves no therapeutic purpose, continuation of such treatment would not be in the patient’s best interest. The Court further held that allowing withdrawal of such treatment in these circumstances does not amount to active euthanasia but falls within the legally permissible domain of passive euthanasia grounded in dignity under Article 21 of the Constitution.
Summary: The case concerned Harish Rana, a 32-year-old man who had suffered severe traumatic brain injury in 2013 after a fall from the fourth floor of his accommodation and had since remained in a permanent vegetative state with 100% permanent physical disability, quadriplegia, tracheostomy support and artificial feeding through a PEG tube. His parents had been caring for him continuously for more than thirteen years and approached the Court seeking evaluation under the Common Cause framework for withdrawal of life-sustaining treatment. The Supreme Court directed constitution of a primary medical board and thereafter a secondary medical board at AIIMS, New Delhi. Both boards found that Harish had irreversible, non-progressive brain damage, fulfilled the criteria for permanent vegetative state, had no chance of improvement, and that continued clinically assisted nutrition and hydration was necessary only for biological survival and not for any medical recovery. The Court also considered the consistent and deeply considered views of the parents and siblings, who expressed that continuation of treatment no longer served any meaningful purpose and only prolonged suffering and indignity. In a detailed judgment, the Court revisited the jurisprudence of Common Cause (2018) and Common Cause (2023), clarified the distinction between active and passive euthanasia, held that withdrawal of CANH amounts to withdrawal of medical treatment and not intentional causing of death, and emphasised that the governing test is the patient’s best interest, assessed from both medical and welfare perspectives. The Court concluded that in the peculiar facts of the case, all relevant considerations pointed only in one direction, namely that continued artificial prolongation of life was inconsistent with the applicant’s dignity and best interests.
Decision: The Supreme Court allowed the miscellaneous application and directed that, in view of the concurrence of the primary and secondary medical boards, the consequences contemplated by the Common Cause guidelines shall operate, thereby permitting withdrawal of life-sustaining medical treatment including clinically assisted nutrition and hydration being administered to Harish Rana, with appropriate palliative care and medical supervision so that nature may take its course with dignity.