Francis Coralie Mullin v. Administrator, Delhi (1981) – Article 21 and the Right to Live with Dignity: A Landmark Case on Human Rights in India
Introduction Article 21 of the Indian Constitution states: “ No person shall be deprived of his life or personal liberty except according to the procedure established by law. ” While this may appear straightforward, its interpretation has undergone a significant evolution through judicial pronouncements. One of the landmark cases that shaped the modern understanding of this provision is Francis Coralie Mullin v. Administrator, Union Territory of Delhi (1981) . This case transformed Article 21 by emphasizing that the right to life is not limited to mere physical existence—it includes the right to live with human dignity , access to essential needs, and humane treatment, even for those in custody. This ruling laid the groundwork for subsequent human rights jurisprudence in India, particularly in the context of prisoners' rights and preventive detention laws . Background of the Case Francis Coralie Mullin, a British national, was detained under the COFEPOSA Act, 1974 (Conserva...