In balancing right to health under Article 21 with intellectual property rights, the Supreme Court has applied which principle to allow compulsory licensing of life-saving drugs to ensure affordability while respecting patent rights?

Health rights and pharmaceutical access: (a) Constitutional basis: Article 21 (right to health) balanced with TRIPS Agreement, Patents Act provisions on intellectual property, (b) Proportionality application: (i) Legitimate aim: Public health (access to affordable medicines) vs. innovation incentives (patent protection), (ii) Rational connection: Compulsory licensing suitable to achieve affordable access while maintaining patent system, (iii) Necessity: Less restrictive alternatives considered (voluntary licensing, price negotiation) before compulsory licensing, (iv) Balancing: Benefits of affordable access vs. harm to innovation incentives; calibrated approach ensures both public health and innovation, (c) Applications: (i) Compulsory licensing: Bayer-Natco case (2012) allowed compulsory license for cancer drug, balancing patent rights with public health, (ii) Price regulation: Drug price control orders ensure affordability while allowing reasonable profits, (iii) Generic medicines: Promoting domestic production of affordable generics under TRIPS flexibilities, (d) Challenges: (i) Innovation concerns: Ensuring patent system continues to incentivize R&D for new drugs, (ii) Access gaps: Ensuring affordable medicines reach marginalized populations, rural areas, (iii) Global context: Balancing domestic health needs with international trade obligations, (e) Illustrates calibrated rights balancing: Article 21 interpreted to require affordable healthcare; proportionality ensures balanced approach to pharmaceutical access, innovation incentives.