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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?
- Maneka Gandhi v. Union of India (1978)
- Paschim Banga Khet Mazdoor Samity v. State of West Bengal (1996)
- Parmanand Katara v. Union of India (1989)
- Consumer Education and Research Centre v. Union of India (1995)
Answer: Parmanand Katara v. Union of India (1989)
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.