The Meaning of ‘Life’ under the Indian Constitution applied the international norm of avoidance of statelessness where persons were at risk of being rendered stateless through governmental action. 100 1 Nationality as a Necessity for Enjoyment of a Dignified ‘Life’ As noted previously, the obligation not to render persons stateless is applicable to India. A person without nationality does not enjoy the right to nationality and so does not possess membership in a state or enjoy a dignified life. A loss, deprivation or denial of nationality would mean the denial of a core right that enables a human being to exist and not to just possess but claim all human rights. Under art 21 of the Constitution, no person can be deprived of their right to a quality, dignified life. If there was a right that acted as a necessary component in the enjoyment and not just the entitlement to the right to life guaranteed under art 21, the former right has to be assured so the latter right can be enjoyed. The right to nationality is that ‘precursor’ right to enjoy a dignified life. 101 In this sense, if art 21 mandates the state to guarantee the right to life of all persons, it means that the state cannot render someone stateless, cutting off such persons from the rights under art 21. Human rights constitute minimum protections and the practices to realise such protections. 102 So, a person can be considered to have human rights in not just possessing rights but in being able to enjoy those rights. A person may be entitled to all or some human rights but in rendering them stateless, the state exposes them to a situation where they may not be able to enjoy these rights. It follows that for the enjoyment of all rights constituting ‘life’, a person must be assured that they are not rendered stateless. Where state action renders a person stateless, such a person finds themselves in a place where they are, in effect, not entitled to the right to a dignified life under art 21. Accordingly, a person must be guaranteed the right to have rights to enjoy the right to life, which constitutes the right to several other human rights. The loss or deprivation of the right to have rights would result in the violation of the right to other human rights or the right to life. A similar logic was followed by the Madras High Court in P Ulaganathan, where the Court considered the problems faced by those who were left in a situation of statelessness for 35 years and called this a violation of the right to life itself. 103 Therefore, given the importance of nationality for the enjoyment of the right to life, the right to nationality and the consequent obligation not to render persons stateless are necessary for the enjoyment of ‘life’ under art 21. 100 See, Gangadhar Yashwant Bhandare v Erasmo Jesus De Sequiria (1975) 1 SCC 544 (Supreme Court of India) [22]–[23]; Prabhleen Kaur v Union of India (Delhi High Court, Bakhru J, 3 October 2018) (‘Prabhleen Kaur’) [35]; Ramesh Chennamaneni v Union of India (Telengana High Court, Naveen Rao J, 10 July 2019) (‘Ramesh Chennamaneni’)[48]–[50]; P Ulaganathan (n 73) [14]; Mangal Sain v Shanno Devi AIR 1959 P&H 175 (Punjab-Haryana High Court) [17]; Jasmeet Kaur v Navtej Singh (Delhi High Court, Kohli and Sharma JJ, 19 September 2017) [29]. 101 Batchelor (n 27) 159. 102 Jack Donnelly, Universal Human Rights in Theory and Practice (Cornell University Press 2003) 17. 103 P Ulaganathan (n 71) [14]. 199