The Supreme Court in SUBHASH KUMAR v. STATE OF BIHAR, AIR 1991 SC 420 held that:
Answer & Solution
Correct answer: C.
1. In Subhash Kumar v. State of Bihar (1991), the Supreme Court explicitly held: 'Right to live is a fundamental right under Article 21 of the Constitution and it includes the right of enjoyment of POLLUTION FREE WATER AND AIR for full enjoyment of life.'
2. The judgment expanded Article 21's protection of life to include environmental quality.
3. The Court widened the scope of PIL (public interest litigation) in environmental matters.
4. Earlier hints came in Bandhua Mukti Morcha (1984), M.C. Mehta cases (1986 onwards).
5. Hence option B is correct.
_Source: EPA 1986 / Constitution of India / Stockholm/Rio/Paris / Indian SC environmental jurisprudence — Subhash Kumar v. State of Bihar, AIR 1991 SC 420_
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