released forthwith, considering the requirement of protection of right to life and liberty of the citizen against the lawlessness of the state. · ● · ● · In a Public Interest Petition Dr. Upendra Baxi vs. State of Uttar Pradesh & others was filed before the Hon’ble Court (1981) to enforce human rights of protective home inmates at Agra, UP, who were kept in abject dehumanized living conditions, the Hon’ble court issued various appropriate directions from time to time in order to ensure that the inmates of the Protective Home at Agra do not continue to live in inhumane and degrading conditions and that the right to life with dignity enshrined in Article 21 of the Constitution is made real and meaningful for them. In a set of Public Interest Petitions B.R.Kapoor & others vs Union of India and others (1983) and PUCL & Others vs Union of India & others (1983) filed before the Hon’ble Court regarding Shahdara Mental Hospital, Delhi, Hon’ble court observed that the Mental Hospital located at the capital of the country should be run by the Union of India and not by Delhi Administration. The Hon’ble court directed that the Mental hospital located at Shahdara should be modelled on the lines of similar psychiatric speciality obtaining at the institution run by NIMHAS at Bangalore, and also directed to examine as to whether the hospital could be attached to a teaching institution which has post graduation specialization in Psychiatry, Neurology and Neuro – Psychiatry. This led to the formation of the Institute of Human behaviour and Allied Sciences, IHBAS. In the case of Chandan Kumar Bhanik vs. State of West Bengal (1988) the apex Court observed: “Management of an institution like the mental hospital requires flow of human love and affection, understanding and consideration for mentally ill persons; these aspects are far more important than a routinized, stereotyped and bureaucratic approach to mental health issues”. In the case of Sheela Barse vs. Union of India and others (1993) the apex Court observed that admission of non-criminal mentally ill persons in jails is illegal and unconstitutional; All mentally ill persons kept in various central, district and sub jails must be medically examined immediately after admission; Specialised psychiatric help must be made available to all inmates who have been lodged in various jails/sub jails; Each and every patient must receive review or revaluation of developing mental problems; A mental health team comprising clinical psychologists, psychiatric nurses and psychiatric social workers must be in place in every mental health hospital. The apex Court in its judgement in Rakesh Chandra Narayan vs. State of Bihar (1986) had laid down certain cardinal principles. These are: Right of a mentally ill person to food, water, personal hygiene, sanitation and recreation is an extension of the right to life as in Article 21 of the Care and Treatment in Mental Health Institutions– Some Glimpses in the Recent Period 13