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Best Interest Principle In Passive Euthanasia Jurisprudence (2026 Lens): Comparative Analysis Of The Supreme Court’s 2026 Refinements To

Best Interest Principle In Passive Euthanasia Jurisprudence (2026 Lens): Comparative Analysis Of The Supreme Court’s 2026 Refinements To Common Cause Guidelines On Withdrawing Artificial Nutrition/Hydration, Exploring Dignity, Autonomy, And Non-Voluntary Cases Through Natural Law Vs. Positivist Lenses





Arpita Pandey, SMS Law College, Khushipur, Varanasi.


ABSTRACT


The Supreme Court of India’s judgment in Harish Rana v. Union of India (2026 INSC 222, decided 11 March 2026) marks the first comprehensive application of the passive euthanasia framework laid down in Common Cause v. Union of India (2018). This article analyses the Court’s 2026 refinements, particularly the classification of Clinically Assisted Nutrition and Hydration (CANH) as medical treatment, the elaboration of the “best interest” principle, procedural streamlining, and mandatory palliative care. Focusing on non-voluntary cases involving patients in persistent vegetative state (PVS), it examines how these refinements balance dignity and autonomy under Article 21. Through a comparative philosophical lens, the article argues that while the judgment employs positivist procedural tools for predictability and safeguards, its substantive core draws upon natural law principles of inherent human dignity and qualitative flourishing. The analysis highlights the need for parliamentary legislation to codify this evolving jurisprudence.


Keywords: Passive euthanasia, Best interest principle, CANH withdrawal, Article 21, Dignity, Autonomy, Natural law, Legal positivism, Harish Rana (2026).



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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