The Code of Criminal Procedure which contains some general provisions to cover ordinary situations came to be regarded as an instrument to combat pollution in 1980s and was utilized in one of the following cases:
A. Subhash Kumar v. State of Bihar
B. Charan Lal Sahu v. Union of India
C. Andhra Pradesh State Pollution Control Board v. Prof M. V. Naidu
D. Municipal Council Ratlam v. Vardichand
Answer: Option D
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