The Meaning of ‘Life’ under the Indian Constitution protection to such persons. 108 Given this trend, it is not an untenable implication that including the obligation not to render persons stateless under art 21 could give rise to an obligation on the state to grant citizenship to stateless persons with no links to any other country. 3 Procedure Established by Law and Exceptions to the Obligation Not to Render Persons Stateless In this Part so far, it has been established that art 21 should include an obligation on the state not to render persons stateless. If ‘life’ includes the state obligation not to render persons stateless, then any exception to such an obligation has to be in accordance with procedure established by law, a limitation on the right to life provided by art 21. ‘Procedure established by law’ under art 21 has been interpreted by the Supreme Court of India to mean that the law itself should be fair, just and reasonable. 109 This posits the existence of a law as a first requirement. 110 In relation to the obligation not to render persons stateless, there should first be a law in existence that specifically mentions how and when statelessness can be created. Harmoniously reading international law on the obligation on states to avoid statelessness with Indian law, this should, as a minimum, not go beyond what are accepted in international law as exceptions for creating statelessness. The Supreme Court has established that to assess if a law is fair, just and reasonable, what is to be examined is the legitimate state aim and proportionality of the legislation. 111 If the legislation pursues a legitimate goal (legitimate goal stage), there is a suitable means of furthering the goal (suitability stage), there is an alternative measure which could achieve that purpose with a lesser degree of limitation (necessity stage) and it does not have a disproportionate effect on the right holder (balancing stage), a limited infringement of rights will be valid. 112 So, any state action that does not comply with the obligation not to render persons stateless, which should be part of art 21, has to be tested to see if the action is based on procedure established by a just, fair and reasonable law. In fact, these requirements echo the limitations on state action causing statelessness under international law namely that such state action is to be non-discriminatory, for a legitimate purpose that is in accordance with international law and that the action is to be proportional to the consequences that would befall the person rendered stateless and the interest of the state that is being protected by the state action. 113 While the following Part will test the NRC against the above requirements, this article argues that the obligation not to render persons stateless should generally be part of art 21. To illustrate this, consider Ramesh Chennamaneni v Union of India and Others, where the Telengana High Court ruled that the deprivation of 108 Prabhleen Kaur (n 100) [39]–[40]; Sheikh Abdul Aziz v State NCT of Delhi (Order) (2014) 109 110 111 112 113 WP(Crl) 1426/2013 (Delhi High Court) (Bhasin and Waziri JJ); Sheikh Abdul Aziz v State NCT of Delhi (Order) (2014) WP(Crl) 1426/2013 (Delhi High Court) (Baht and Sanghi JJ). Maneka Gandhi (n 81) [48]. Dr Subhash Kashinath Mahajan v The State of Maharashtra (2018) SC 1498 (Supreme Court of India) [12]. Justice KS Puttaswamy v Union of India (2017) WP(C) No 494 of 2012 (Supreme Court of India) [180] (Khehar CJI, Chelameswar, Bobde, Agrawal, Nariman, Sapre, Chandrachud, Kaul and Nazeer JJ) (‘Justice KS Puttaswamy’). Justice KS Puttaswamy (n 113) [125]–[126]. See Part 2(B). 201