Starvation deaths had occurred in the state of Rajasthan, despite excess grain being kept for official times of famine, and various schemes throughout India for food distribution were also not functioning. In 2001, the People's Union for Civil Liberties (PUCL) petitioned the court for enforcement of both the food schemes and the Famine Code, a code permitting the release of grain stocks in times of famine. They grounded their arguments on the right to food, deriving it from the right to life.