Constitutional right to privacy affirmed as part of life, liberty, dignity, and overlapping fundamental freedoms.

Privacy was recognised as an inalienable constitutional right protected under Part III, especially as part of life, personal liberty, dignity, and related freedoms. The Court rejected the earlier view that fundamental rights operate in isolated compartments, holding instead that Part III rights overlap and reinforce one another. Privacy may be developed case by case and is protected against State intrusion, subject to the constitutional standard applicable to the specific freedom affected. The contrary observations in M.P. Sharma and the majority view in Kharak Singh were held inconsistent with later doctrine and overruled to that extent.

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Issues: Whether the right to privacy is a constitutionally protected fundamental right under Part III of the Constitution, and whether the contrary observations in the earlier decisions in M.P. Sharma and the majority in Kharak Singh continue to hold the field.

Analysis: The right to privacy was held to be inherent in the constitutional guarantees of life, personal liberty, dignity, and other freedoms in Part III. The earlier approach treating fundamental rights as isolated silos was rejected in light of the later doctrine that rights in Part III are overlapping and mutually reinforcing. The Court held that privacy is an inalienable and natural right which the Constitution protects against State intrusion, and that its content must be developed case by case. The contrary observations in M.P. Sharma and the majority view in Kharak Singh were found inconsistent with later constitutional doctrine and were overruled to that extent.

Conclusion: The right to privacy is protected as a fundamental right under the Constitution, principally under Article 21 and also in relation to other freedoms in Part III. The prior contrary statements in M.P. Sharma and the majority in Kharak Singh were overruled to that extent.

Ratio Decidendi: Privacy is an inalienable constitutional right that forms part of the guarantees of life, personal liberty, dignity, and other freedoms in Part III, and any State action infringing it must satisfy the constitutional standards applicable to the specific freedom affected.

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