Introduction 

• In this case Right to livelihood and shelter were held as an integral part of Right to live. 

Facts 

• In this case as a part of beautification drive the State of Maharasthra and Bombay Municipal Corporation decided to remove pavement dwellers. 
• The petitioner argued that removing them from their places would cause greater harm to them and would be harsh on them. 
• It was also contented that it in violation of Article 21 and Article 19 of the Constitution of India (COI). 
• A Special leave petition was filed by the petitioner, a journalist challenging the validity of eviction notice. 

Issue Involved

• Whether the eviction notices are in violation of fundamental rights guaranteed under Article 19 and Article 21 of the COI of the pavement dwellers? 

Observations

• The Supreme Court in this case held that Right to live under Article 21 also includes Right to livelihood which is in relation with Right to shelter. 
• The apex court also stated that without giving them alternate remedy to live would be in contravention to their fundamental rights. 

Conclusion 

• The Supreme Court held that Article 21 guarantees Right to live in a dignified way and not merely animal existence. It was stated that Article 21 is a bundle of rights required to live in a dignified manner such as the right to privacy, health, education, shelter, etc. 
• Therefore, it was held that without giving pavement dwellers an alternate place to live is not just and reasonable as per the constitution of India.