Key Terms & Concepts — UPSC Mains
Francis Coralie Mullin v. Administrator, UT of Delhi (1981)
"The Supreme Court judgment holding that the right to life under Article 21 includes the right to live with human dignity, not merely physical survival."
Francis Coralie Mullin v. Administrator, Union Territory of Delhi (1981) concerned a detainee's right to be visited by family and counsel under COFEPOSA. The Supreme Court, through Justice P.N. Bhagwati, held that the right to life under Article 21 does not mean mere animal existence, but the right to live with human dignity, including bare necessities such as adequate nutrition, clothing and shelter, and facilities for reading, writing and self-expression. The judgment moved Article 21 beyond a negative guarantee against arbitrary deprivation toward a positive conception of dignified existence, building directly on Maneka Gandhi v. Union of India (1978).
Prelims tests the case name and its 'right to live with dignity' holding; Mains uses it to trace how Article 21 evolved into an entitlement to the conditions that make a dignified life possible.
- 1 Decided by the Supreme Court in 1981, authored by Justice P.N. Bhagwati.
- 2 Held that Article 21's right to life includes the right to live with human dignity, not mere animal existence.
- 3 Named bare necessities: adequate nutrition, clothing, shelter, and facilities for self-expression.
- 4 Built on Maneka Gandhi v. Union of India (1978) and preceded Olga Tellis v. Bombay Municipal Corporation (1985).
The 2026 footpath judgment's Article 21 lineage traces through Francis Coralie Mullin's 1981 holding on dignity, en route to recognising safe pedestrian infrastructure as a constitutional entitlement.
