Answer & Solution
Answer: Option
D
Solution:
1. Correct Option: Subash Kumar v. State of Bihar (1991)
* In this landmark case, the Supreme Court of India very clearly stated that the Right to Life under Article 21 of the Constitution includes the right to enjoy pollution-free water and air. The court emphasized that if the air or water is polluted, it affects a person's life and health, thereby infringing their fundamental right to life. This case was a crucial step in linking environmental protection directly with fundamental rights.
2. Why other options are not the primary answer for this specific question:
* Option A: Francis Coralie Mullin v. The Administrator, Union Territory of Delhi (1981)
* This case significantly expanded the meaning of the "right to life" and "personal liberty" under Article 21. It said that the right to life is not just about physical existence but also about living with human dignity and all that goes with it. While crucial for expanding Article 21, it didn't specifically focus on unpolluted air and water.
* Option B: Rural Litigation and Entitlement Kendra, Dehradun v. State of Uttar Pradesh (1987)
* This was one of the first major environmental cases in India, often called the "Dehradun Valley Limestone Quarrying Case." The Supreme Court used Article 21 to stop environmentally destructive mining activities. It was a groundbreaking case for environmental protection and connected it to the right to life, but the explicit declaration that the right to life *includes the right to enjoy unpolluted air and water* was more distinctly articulated in the Subash Kumar case.
* Option C: S. Jagannath v. Union of India (Shrimp Culture Case) (1996)
* This case dealt with the environmental damage caused by commercial aquaculture (shrimp farming) along coastal areas. The Court applied the "Precautionary Principle" and "Polluter Pays Principle," holding them as part of environmental law in India. While very important for environmental law and protection, its primary focus was on regulating industries and applying specific environmental principles, rather than the general declaration about unpolluted air and water as part of the right to life itself.
