Parmanand Katara vs Union of India & Ors
📌 Background of the Case
A young boy was injured in a road accident in Delhi and was taken to a private hospital.
The hospital refused treatment because the patient could not pay immediately and insisted on police formalities.
Due to this denial of emergency care, the boy’s condition worsened, leading to death.
Parmanand Katara, a public-spirited individual, filed a public interest litigation (PIL) against the Union of India, Delhi Administration, and hospital authorities.
📌 Legal Issues
Whether denial of emergency medical care violates Article 21 of the Constitution (Right to Life).
Whether the State and private hospitals have a legal duty to provide emergency treatment without delay.
📌 Court’s Reasoning
Article 21 – Right to Life
The Supreme Court observed that right to life includes the right to live with human dignity.
Access to emergency medical care is a part of the right to life.
Duty of Hospitals
Both government and private hospitals have a duty to save life in emergency situations.
Refusal to provide immediate treatment cannot be justified on the ground of payment or procedural formalities.
Public Duty and Negligence
Negligence in providing emergency medical care can lead to constitutional liability.
Hospitals cannot hide behind rules or bureaucracy when a life is at risk.
Proactive Role of Judiciary
The Court emphasized that judges can intervene to enforce fundamental rights even in cases of medical negligence or administrative inaction.
📌 Judgment
The Supreme Court held:
Right to life includes right to emergency medical treatment.
Hospitals must provide immediate medical care irrespective of payment or police formalities.
Negligence leading to death violates Article 21.
Directions were issued for government and private hospitals to ensure prompt emergency care.
📌 Principle (Case Law Rule)
Parmanand Katara v. Union of India (1989) established that:
Right to life under Article 21 includes the right to emergency medical care.
Hospitals, public or private, have a constitutional and legal duty to provide emergency treatment.
Denial or delay in medical aid due to formalities or payment issues is unconstitutional.
✅ In short: This case is a landmark in medical law and fundamental rights, emphasizing that saving human life cannot be denied for bureaucratic or financial reasons.
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