(2017) 1 African Human Rights Yearbook 89 the right to life imposes positive obligations on states to prevent loss of life.35 For example, in Laxmi Mandal v Deen Dayal Haringar Hospital; and Jaitun v Maternity Home, an Indian High Court found that death occasioned by lack of access to maternal health care services amounted to a violation of the right to life guaranteed in the Constitution.36 This approach would seem to reaffirm the positive nature of the duty imposed by the right to life as well as reinstate the indivisibility and interrelatedness of all rights including the rights to health and life. It is consistent with the reasoning of some United Nations treaty monitoring bodies (UNTMBs) who have emphasised that deaths arising from poor or lack of access to maternal health care services will amount to the violation of the right to life. For instance, the Human Rights Committee in its General Comment 6 has explained that the right to life should not be construed narrowly but that it intersects with other rights such as housing, food and health care.37 The Human Rights Committee has equally noted in its Concluding Observations that lack of access to reproductive health care services, including emergency obstetric care and services related to contraception for women, is a violation of their right to life.38 In particular, the Committee has consistently expressed grave concern over high rates of maternal mortality, framing it as a violation of women’s right to life.39 The broad interpretation of states’ obligation to guarantee the right to life in instances of preventable maternal deaths has also been explicitly recognised by the African Commission in its concluding observations, and most recently in its General Comment 3 on the Right to Life.40 The African Commission specifically noted that states have a responsibility to address chronic but pervasive threats to life such as preventable maternal deaths by establishing functioning health systems and eliminating discriminatory laws and practices that restrict access to healthcare services.41 35 See Pachim Banga Khet Majoor Samity v State of West Bengal (1996) 4 SCC 37. The Court held that failure on the part of a government hospital to provide emergency treatment to a citizen amounted to a violation of the right to life guaranteed under article 21 of the Indian Constitution 36 Laxmi Mandal v Deen Dayal Haringar Hospital; and Jaitun v Maternity Home, MCD, MANU/DE/1268/2010, cases WP(C) 8853/2008 and 10700/2009 (High Court of Delhi) judgment on 04.06.2010. 37 HRC General Comment 6: The Right to Life UN GAOR Human Rights Committee 37th session Supp No 40 para 6. 38 See HRC Concluding Observation: Chile 30/3/99 UN Doc CCPR/79/Ad. 104,para 15. 39 See for instance HRC Concluding Observations: Bolivia 01/04/97 UN Doc. CCPR/ 79/Ad. 74, 22; Concluding Observation: Guatemala 27/08/2001 UN Doc CCPR/CO/ 72GTM, para 19. 40 African Commission on Human and Peoples’ Rights General Comment 3: the right to life Paras 3 and 42 available at http://www.achpr.org/files/instruments/generalcomments-right-to-life/general_comment_no_3_english.pdf (accessed 14 July 2017). 41 As above.