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The ambit of Article 21 have expanded over the years through judicial precedents.

According to article
21, a person can be deprived of his life and personal liberty according to a procedure established by
law. Justice Iyer said, “the spirit of the man is at root of article 21. Personal liberty makes the worth of
human person and travel makes Liberty worthwhile.”

Different Aspects Of Article 21


Right to Live with Dignity
Supreme Court has given a broad and liberal interpretation to the term life as used in Article
21. Justice Bhagwati, in Francis Coralie Vs. U.T. of Delhi (1981 SC), had observed, “we think
that right to life includes the right to live with human dignity and all that grows along with it
namely, the bare necessities of life such as the adequate nutrition, clothing and shelter over the
head and facilities for reading, writing and expressing oneself. The protection extends to all those
limbs of body by which the life is enjoyed”.

In Bandhua Mukti Morcha Vs. Union of India (1984 SC), Justice Bhagwati reiterated his view
and held that it is the fundamental right of every person in this country to live with human dignity
which is free from exploitation. This right to live with human dignity is enshrined under article 21
drives its life breath from the DPSP.

Right To Life Extends To Livelihood


In 1960, the Hon’ble Supreme Court was of the view that Article 21 of Indian Constitution does
not guarantee right to livelihood. The right to livelihood is born out of the right to life, as no person
can live without the means of living, that is, the means of livelihood.

In Olga Tellis Vs. Bombay Municipal Corporation (1986 SC) court has observed that, “ one
aspect of the right to life an equally important facet of that right is the right to livelihood because,
no person can live without the means of living, that is, the means of livelihood.”

If the right to livelihood is not treated as part and parcel of the constitutional right to life, the easiest
way of depriving a person of his right to life would be to deprive him of his means of livelihood
to the point of abrogation.

Right to Education
Right to education is one of the most important aspect human beings without which no one can
lead good, decent and dignified life. Earlier, it was the part of Directive Principles of State Policy.
However as per the changing needs of the society Supreme Court in Mohini Jain Vs. State of
Karnataka (1992 SC) and Unni Krishna Vs. state of Andhra Pradesh (1993 SC) ruled that
right to education is a fundamental right as it directly flows from right to life.
Earlier the Court interpreted right to education under article 21 but in the year 2002, by
constitutional amendment, article 21-A was inserted to the Indian Constitution and right to
education was expressly made as a fundamental right.

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