The Punjab and Haryana High Court has flagged the need to revisit and strengthen public health infrastructure, observing that the Right to Health is an integral component of the Right to Life guaranteed under Article 21 of the Constitution of India. The Court made these observations while adjudicating a matter relating to healthcare services.
Right to Health as a Fundamental Right
While the Indian Constitution does not expressly enumerate the right to health as a fundamental right, the Supreme Court has through a series of judgments recognised it as a component of the right to life under Article 21. In Paschim Banga Khet Mazdoor Samity v. State of West Bengal (1996), the Supreme Court held that failure to provide timely medical treatment to a person in need constitutes a violation of the right to life.
Subsequently, in State of Punjab v. Ram Lubhaya Bagga (1998), the Supreme Court reiterated that the right to health is integral to the right to life and that the state has an obligation to provide adequate medical facilities and ensure equitable access to healthcare.
Punjab and Haryana High Court’s Observations
The High Court noted that despite constitutional guarantees and legislative provisions, the state of public health infrastructure in many parts of India remains inadequate. The Court observed that the gap between the constitutional right to health and the actual provision of healthcare services must be addressed through systematic improvements in infrastructure, personnel, and resources.
The Court called for a comprehensive review of medical infrastructure in the state to ensure that the constitutional promise of the right to health is translated into reality for all citizens, particularly those in rural and underserved areas.
Healthcare Infrastructure Gaps
India has made significant progress in healthcare indicators over the past few decades, but significant gaps remain. Rural healthcare infrastructure continues to face challenges including shortage of doctors, nurses, and paramedical staff; inadequate medical equipment; and poorly maintained facilities. The COVID-19 pandemic starkly exposed these gaps, leading to renewed focus on strengthening public health infrastructure.
Judicial Role in Healthcare
Indian courts have played an active role in holding governments accountable for the state of public health services. High Courts and the Supreme Court have regularly intervened in matters involving the right to health, directing improvements in hospital infrastructure, availability of essential medicines, and quality of care in government hospitals.
Court: Punjab and Haryana High Court | Source: LiveLaw | June 2026
