CASE COMMENTARY ON GIAN KAUR V STATE OF PUNJAB (1996)

AUTHOR – BANSHIKA GUPTA, STUDENT AT SCHOOL OF LAW, DAVV UNIVERSITY, INDORE (M.P.).

BEST CITATION – BANSHIKA GUPTA, CASE COMMENTARY ON GIAN KAUR V STATE OF PUNJAB (1996), INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (8) OF 2026, PG. 626-629, APIS – 3920 – 0001 & ISSN – 2583-2344

ABSTRACT

The landmark judgment in Gian Kaur v State of Punjab reshaped the constitutional discourse on life, dignity, and death in India. At its core, the case questioned whether the “right to life” under

Article 21 could be stretched to include a “right to die.” Confronting this complex issue, the Supreme Court firmly rejected the notion, holding that life and death are conceptually incompatible within the constitutional framework. By overruling P. Rathinam v. Union of India, the Court restored the validity of Sections 306 and 309 IPC, while drawing a nuanced distinction between suicide and its abetment. Importantly, the judgment acknowledged that dignity in life extends until its natural end, opening the door to discussions on dignified death in exceptional circumstances. Balancing individual autonomy with societal interests, the ruling remains a cornerstone in Indian constitutional law, influencing debates on euthanasia, mental health, and the evolving meaning of human dignity.