In OLEUM GAS LEAK CASE (M.C. Mehta v. Union of India), AIR 1987 SC 965, the Supreme Court read the right to a CLEAN ENVIRONMENT into:

1. M.C. Mehta v. UoI (Oleum Gas Leak) and subsequent cases established that the right to a CLEAN AND HEALTHY ENVIRONMENT is part of the RIGHT TO LIFE under Article 21 of the Constitution. 2. Subhash Kumar v. State of Bihar (1991) made this explicit: '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.' 3. Subsequent cases: Virender Gaur (1995); Indian Council for Enviro-Legal Action (1996); A.P. Pollution Control Board v Prof. MV Nayudu II (2001); Karnataka Industrial Areas Development Board v Sri C. Kenchappa (2006). 4. Hence option B is correct. _Source: EPA 1986 / Constitution of India / Stockholm/Rio/Paris / Indian SC environmental jurisprudence — M.C. Mehta v. Union of India (Oleum Gas Leak), AIR 1987 SC 965; Subhash Kumar v. State of Bihar, AIR 1991 SC 420_