THe sublime margaret court on midweek observed that the demise of Harish genus rana, who became the first person in India to be allowed passive euthanasia after spending more than 13 years in a permanent vegetative state, symbolised dignity not only in life but also in death, as it received a report from AIIMS detailing his final days in palliative care.A bench of justices JB Pardiwala and KV Viswanathan said Rana’s passing underscored the limits of medicine and the importance of respecting a patient’s autonomy at the end of life.“It also serves as a reminder that medicine has its limits and prolonging life in ways a person would not choose themselves is not true care. Allowing someone to pass on their own terms and alleviating their suffering affirms their dignity and honours their ultimate control,” noted the bench.The court recorded in its order that pursuant to its March 11 judgment permitting withdrawal of clinically assisted nutrition and hydration (CANH), Rana was shifted from his Ghaziabad residence to the palliative care unit at All India Institute of Medical Sciences on March 14. He passed away there on March 24.“Harish left the mortal world on his own terms, surrounded by love and compassion,” said the bench, adding that even in the face of personal loss, Rana’s family chose to donate his corneas and heart valve.“Through this act, his life continues in others. His legacy will live on in the lives of those he saved,” the court said.During the hearing, the bench was informed that Rana’s organs could be donated only partially because of his medical condition. The bench asked whether organ donation had taken place, to which counsel appearing for the petitioner family replied that the corneas and heart valve had been donated and an appreciation letter from the hospital had been placed on record.The court directed that Rana’s death certificate dated April 7 and the report submitted by AIIMS be preserved as part of the judicial record, with the medical report kept in sealed cover. It also recorded appreciation for the doctors and medical staff at AIIMS who attended to Rana during his final days in palliative care.“This litigation has taught many things to one and all, including two of us as judges,” observed the bench, commending the counsel for Rana’s family, Rashmi Nandakumar, for assisting the court.Additional solicitor general Aishwarya Bhati appeared for the Union government. The matter will now be taken up again in July for monitoring compliance with the directions issued in the March judgment regarding constitution of medical boards and identification of judicial officers under the passive euthanasia framework.In its historic March 11 ruling, the Supreme Court had invoked the Shakespearean dilemma of “to be or not to be” while permitting withdrawal of life-sustaining medical treatment for Rana, holding that artificial prolongation of life cannot continue once treatment ceases to serve the patient’s dignity or best interests.Rana, a former engineering student of Panjab University, had remained in a permanent vegetative state since 2013 after suffering catastrophic head injuries in a fall from the fourth floor of his paying guest accommodation in Chandigarh.The bench had held that clinically assisted nutrition and hydration administered through a PEG feeding tube amounted to medical treatment and could therefore be withdrawn under the passive euthanasia framework evolved by the Supreme Court in the 2018 Common Cause judgment on passive euthanasia ruling.The court had clarified that the decision was “not about choosing death” but about refusing to artificially prolong life where treatment had become medically futile.“Our decision today does not neatly fit within logic and reason alone. It sits in a space between love, loss, medicine and mercy,” the March judgment had said.Both judges had stressed that withdrawal of treatment should not amount to abandonment of the patient and must instead transition into structured palliative and end-of-life care aimed at minimising suffering and preserving dignity.The court had also urged Parliament to enact a comprehensive legislation on end-of-life care, observing that the absence of a statutory framework had repeatedly forced constitutional courts to step in and fill the vacuum.
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