Fact of the case :
The case concerned two petitions that P. Rathinam (Petitioner 1) and Nagbhushan Patnaik (Petitioner 2) concurrently submitted. The petitioner attempted suicide as a result of an uncontrolled situation that had emerged. P. Rathinam, the petitioner, challenged the constitutionality of Section 309 of the Indian Penal Code (IPC), which criminalizes the act of attempting suicide.
Rathinam contended that this provision was a violation of the fundamental right to life and personal liberty guaranteed under Article 21 of the Indian Constitution, arguing that the state should not penalize individuals who are already in a state of severe mental distress.
In its examination, the Court recognized that the right to life under Article 21 encompasses (incorporate) the right to live with dignity, which includes the right to die. The Court noted that criminalizing suicide attempts could be counterproductive and detrimental to individuals in distress, who might require medical and psychological help rather than penal sanctions.
Held :“The Supreme Court declared Section 309 of the IPC unconstitutional, ruling that the provision violated the right to life and personal liberty under Article 21 of the Constitution. The Court held that the right to life includes the right to die, and therefore, criminalizing attempted suicide was inconsistent with the principles of human dignity and compassion”.