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In Parmanand Katara v. Union of India (1989), the Supreme Court held that every doctor (government or private) has duty to provide ______ medical care to accident victims, and right to life under Article 21 includes right to emergency treatment.
- elective
- emergency
- specialized
- experimental
Answer: emergency
Parmanand Katara (1989) emergency medical care duty: (a) Context: Petition regarding denial of emergency treatment to accident victim by private hospital; issue of medical professionals' duty to provide emergency care, (b) Supreme Court holding: (i) Every doctor (government or private) has duty to provide emergency medical care to accident victims, regardless of legal formalities, payment capacity, (ii) Right to life under Article 21 includes right to emergency treatment; preservation of life paramount, (iii) Legal formalities (police report, payment) cannot delay emergency medical care, (c) Applications: (i) Medical ethics: Medical Council of India incorporated emergency care duty in professional ethics code, (ii) Hospital policies: Hospitals established protocols for emergency care, triage systems to prioritize life-saving treatment, (iii) Legal protection: Doctors providing emergency care in good faith protected from legal liability, (d) Subsequent developments: (i) Clinical Establishments Act: Standards for emergency care in registered healthcare facilities, (ii) Judicial enforcement: Courts award compensation for denial of emergency care, direct systemic reforms, (e) Rationale: (i) Sanctity of life: Preservation of life paramount; emergency care essential for saving lives, (ii) Professional duty: Medical profession has ethical, legal duty to preserve life, alleviate suffering, (iii) Public trust: Public relies on medical professionals for emergency care; duty reinforces trust in healthcare system, (f) Illustrates dignity-centric constitutionalism: Article 21 interpreted to require emergency medical care as foundation for preserving life, dignity; professional duty operationalizes constitutional values in healthcare delivery.