BREAKING|Passive Euthanasia: Supreme Court Allows Withdrawal Of Life Support For Harish Rana

The bench of Justice J. B. Pardiwala and Justice K. V. Viswanathan delivered the judgment in the case of Harish Rana, a 32-year-old man who has remained on life support for over 12 years after suffering severe brain injuries that left him in a persistent vegetative state.

The Court directed that the patient be admitted to palliative care at All India Institute of Medical Sciences (AIIMS), where withdrawal of treatment would be carried out through a carefully tailored plan ensuring dignity. Considering the peculiar facts of the case, the Court also waived the usual 30-day reconsideration period prescribed under the Common Cause guidelines.

While examining the issue of passive euthanasia under Article 21, the bench held that any decision to withdraw life-sustaining treatment must satisfy two key conditions laid down in the Common Cause ruling.

1. The intervention in question must qualify as medical treatment, and

2. Withdrawal must be in the patient’s best interest.

The Court noted that Clinically Assisted Nutrition (CAN) constitutes a technological medical intervention rather than mere basic care. Therefore, withdrawal of such treatment can be examined within the passive euthanasia framework.

The bench recounted that Harish Rana was once a bright 20-year-old student of Punjab University when he suffered a fall from his paying guest accommodation, resulting in severe brain injuries.

Although he was discharged after treatment, the injuries left him in a persistent vegetative state. Medical reports before the Court indicated that despite more than a decade of treatment, there has been no improvement in his condition. He experiences sleep-wake cycles but remains entirely dependent on caregivers.

The Court noted that both the primary and secondary medical boards, along with the patient’s next of kin, had concluded that continuation of Clinically Assisted Nutrition should be discontinued.

The bench observed that while doctors are under a duty to preserve life, that duty cannot extend indefinitely when there is no hope of recovery.

“While a doctor’s duty is to apply treatment, that duty no longer sustains when the patient has no hope of recovery and the intervention merely prolongs biological existence,” the Court noted.

The Court emphasised that withdrawal of treatment must always be conducted in a humane and structured manner, guided by the patient’s best interest and the views of family members.

Significantly, the Court clarified that if both the primary and secondary medical boards certify withdrawal of life-sustaining treatment in accordance with the Common Cause guidelines, judicial intervention is not necessary.

In the present case, however, the matter was brought before the Court given that it is among the first cases testing the operational framework of the 2018 judgment. In a concurring opinion, Justice K. V. Viswanathan held that the High Court had erred in concluding that the case fell outside the scope of Common Cause because the patient was not terminally ill.

The judge clarified that terminal illness is not a prerequisite for considering withdrawal of life-sustaining treatment.

A patient in a permanent vegetative state can also qualify for constitution of medical boards to assess withdrawal of treatment, even in the absence of an advance directive.

Recognising practical difficulties in implementing the Common Cause judgment, the Court clarified certain operational aspects of the framework.

It directed that Chief Medical Officers (CMOs) maintain panels of medical practitioners who may be nominated to secondary medical boards examining requests for withdrawal of life-sustaining treatment.

The Court also urged the Union Government to consider enacting a comprehensive law governing end-of-life care.

Additionally, the bench clarified that palliative and end-of-life care can be provided not only in hospitals but also at home or any place chosen by the patient or family, provided adequate medical care is ensured.

Concluding the judgment, the Court acknowledged the unwavering support of the patient’s family over the years. “His family never left his side… To love someone is to care for them even in the darkest times. Our decision today may not fit neatly within logic, but it reflects the realities of love, life and loss,” the bench observed.

Notably, on January 15, the Court had reserved its judgment on a plea seeking permission for passive euthanasia for Harish Rana.

Previously, on December 18, 2025, the Court had said it wished to personally meet the parents of Harish Rana. The Bench had examined a medical report submitted by a secondary medical board from the AIIMS, detailing the patient’s condition and treatment history. Describing the report as “sad”, the Bench had observed, “We cannot keep this boy in this stage.”