In which case did the Supreme Court first recognize right to health as part of right to life under Article 21, obligating the State to provide adequate medical facilities?

Right to health evolution: (a) Parmanand Katara (1989): SC held every doctor (government or private) has duty to provide emergency medical care; right to life includes right to emergency treatment, (b) Paschim Banga (1996): Expanded to hold failure of government hospital to provide timely treatment violates Article 21, (c) Consumer Education (1995): Right to health includes occupational health safeguards for workers, (d) Applications: (i) Ayushman Bharat: Operationalizes right to health through insurance coverage, (ii) Public health infrastructure: Judicial directions for hospital beds, equipment, staff, (iii) Pandemic response: Courts monitored oxygen supply, vaccine distribution during COVID-19, (e) Limits: Right to health subject to resource constraints; State obligation is progressive realization, not immediate guarantee. Illustrates transformative constitutionalism: Article 21 interpreted to impose positive obligations on State for health infrastructure.