Legal confusion in end-of-life care law has remained a key barrier before dying with dignity in India. The history of legal developments on end-of-life care, however, is not linear, and has been marked by continuities, shifts, and a lack of clarity.  This article excavates the history of Indian end-of-life care law to demonstrate how and why confusion has plagued Indian law. It argues that the Supreme Court’s guidelines in its landmark decision in Common Cause v. Union of India were practically unimplementable since they conflated “passive euthanasia” with the “withholding and withdrawing of life sustaining treatment,” disregarded patient autonomy and did not account for a surrogate decision-making framework for patients who lack decision-making capacity. Recently, the Supreme Court modified the Common Cause guidelines to address some of their practical issues, yet these substantive concerns remain relevant for any future legislative intervention on end-of-life care.