The doctrine of ENVIRONMENTAL PUBLIC TRUST was recognised by the Supreme Court in M.C. Mehta v. Kamal Nath, (1997) 1 SCC 388. According to this doctrine:

1. The Public Trust Doctrine, originally from English common law and codified by the US Supreme Court in Illinois Central Railroad v. Illinois, was applied in India by M.C. Mehta v. Kamal Nath (1997). 2. The Court held: 'The State as a trustee is under a legal duty to protect the natural resources. These resources meant for public use cannot be converted into private ownership.' 3. Categories of resources subject to Public Trust: (i) running waters; (ii) air; (iii) sea and sea-shore; (iv) forests and ecologically fragile lands. 4. The trustee duty is enforceable by judicial review. 5. Reaffirmed in: Th. Majra Singh v. Indian Oil Corporation (1999); Intellectuals Forum, Tirupathi v. State of A.P. (2006); Reliance Natural Resources Ltd. v. RIL (2010). 6. Hence option B is correct. _Source: EPA 1986 / Constitution / International Conventions — M.C. Mehta v. Kamal Nath, (1997) 1 SCC 388_