Euthanasia or mercy killing refers to ending a person's life, who has been suffering from some life-threatening disease and is in a vegetative state. This is usually done when the person suffering from a prolonged disease or suffering succumbs to it, in this case, it is called voluntary euthanasia. Whereas, involuntary euthanasia is when a person has lost consciousness due to the perennial pain or is comatose and is no longer in the state to give consent.

Different countries have different viewpoints regarding euthanasia, much of it, depends upon their region, culture, history, ethics, and sense of morality- which differs from person to person. Some countries take a more rigid stand when it comes to euthanasia while others have a neutral approach to it. In India, although there are no laws regarding euthanasia, the 'right to die' is considered to be within the scope of fundamental rights.
In this article, we will delve into the deeper aspects of euthanasia and also understand its judicial evolution with time.

Types of Euthanasia

The concept of euthanasia has been divided into several types based on different criteria, for example;

1. Direct or active euthanasia: This refers to the deliberate killing of the person to end that person's prolonged suffering. This process involves administering an injection to the patient either by the doctor or a third person which results directly in death.
2. Indirect euthanasia: Use of a substance that does not instantly kill the patient but, if used for a prolonged time, affects shortening the life of the patient. This is generally administered to ease the patient's suffering.
3. Passive euthanasia: Discontinuation of life-prolonging measures (for example, a life-support machine is switched off). Passive euthanasia occurs when the patient dies because the medical professionals either don't do something necessary to keep the patient alive or stop doing something that is keeping the patient alive.
4. Assisted suicide: Assisted suicide is the process by which a person, with the help of others, takes drugs to end their life. It is also referred to as physician-assisted suicide (PAS).
    

The Right to Die with Dignity

In the absence of any relevant law about euthanasia, the right to die was considered a fundamental right within the scope of Article 21. It was held, in the case of Common Cause vs Union of India (2018), that the right to die with dignity is also a fundamental right. The 'right to die' with dignity was given to citizens in cases when a patient undergoes serious illness and there is no scope for recovery left. In such a situation, the state guarantees the patient the right to die peacefully to end their prolonged suffering. The right to die with dignity is considered to be at par with the right to life. The debate surrounding this matter is centered on the fact that if the 'right to life' and dignity is guaranteed to citizens, then the 'right to die' with dignity should also be a part of it. However, some argue that the 'right to life' cannot include the 'right to die,' as the latter is morally incorrect. Their argument states that nobody should be given the authority to decide death for themselves or others, as death is inevitably controlled by God. Thus, the 'right to die' is a contentious topic worldwide.
 

Widened Scope of Article 21

Article 21 of the Indian Constitution provides for the protection of life and personal liberty. It states, 'No person shall be deprived of his life and personal liberty except according to the procedure established by law.' The fundamental right provided under Article 21 is considered the most important fundamental right or the heart of fundamental rights, as observed by the Apex Court in the Unni Krishnan case. Whether the 'right to die' is included within the meaning of Article 21 has been deliberated in various landmark cases in India:

• P Rathinam vs UOI (1994): Section 309 of the IPC (attempt to suicide) was declared unconstitutional as it violates Articles 21 and 14. However, the court emphasized that the 'right to life' does not include the 'right to die.'
• Gian Kaur vs State of Punjab (1996): Overruled P Rathinam. Section 309 of the IPC does not violate Articles 21 and 14, and the 'right to life' does not include the 'right to die.'
• Aruna Shanbaug vs UOI (2011): Passive euthanasia was allowed under strict guidelines for patients in a persistent vegetative state.
• Common Cause vs UOI (2018): The SC upheld that the 'right to live with dignity' includes the 'right to die with dignity.' Guidelines for living wills and passive euthanasia were issued.

Conclusion
Hence, to conclude I would like to state that numerous countries legalized euthanasia and honored the right to die. The Netherlands is the first similar country to legalize euthanasia. The UK and US, like India, allow only unresistant euthanasia and criminalize active euthanasia.

India has honored the ' right to die' as a abecedarian right, still, India has no legal frame or procedure regarding euthanasia. thus, there's an imperative need for strict guidelines to apply euthanasia in India along with a proper legal frame to apply unresistant euthanasia.