Hakim Seikh, who was a member of a labor union, Paschim Banga Khet Mazdoorsamity, fell from a train one evening and suffered severe head injuries. He approached, and was turned away from, six different hospitals during one evening. He eventually spent Rs. 17,000.00 (approximately 260 USD) for treatment at the Calcutta Medical Research Institute. The hospitals kept turning him away because they claimed not to have enough beds. One hospital, however, claimed it had inadequate facilities to provide the necessary treatment. Aggrieved by this incident, the Paschim Banga Khet Mazdoorsamity filed a writ petition in the Supreme Court. The primary issue before the Court was whether the lack of available facilities amounted to a denial of Hakim Seikh’s right to life under Article 21 of the Indian Constitution. While the case was pending in the Court, the Respondent, Government of West Bengal, appointed an enquiry Committee (the Committee) to report on why Hakim Seikh was repeatedly denied treatment and to give recommendations to avoid similar incidents form occurring again.