The case of Rural Litigation and Entitlement Kendra, Dehradun v. State of U.P. (1985), also known as the Doon Valley Quarrying Case, is one of the earliest instances where the Supreme Court expanded the scope of Article 21 (Right to Life) to include environmental protection and ecological balance. By ordering the closure of limestone quarries in the Mussoorie hills due to environmental degradation, the court implicitly recognized that the right to life includes the right to a healthy and hygienic environment, free from pollution that endangers health. This laid the groundwork for later, more explicit judgments on the right to health.