1996 case of the Indian Supreme Court on access to emergency health care in the Soobramoney case. In 2017, the European Court of Human Rights also recognised that there exists a right to access to emergency health care in the member states of the Council of Europe. The Council of Europe member states have a positive obligation to protect this right under Article 2 of the European Convention on Human Rights that protects the right to life. References Constitutional Court of South Africa cases 1997 in South African law 1997 in case law