Question

Which of the following public interest litigations expanded Article 21 of the Indian Constitution to include the right to enjoyment of pollution-free water and air?

• A. Subhash Kumar v. State of Bihar, (1991) 1 SCC 598
• B. Nilabati Behera v. State of Orissa, (1993) 2 SCC 746
• C. Sheela Barse v. Union of India, (1986) 3 SCC 596
• D. Olga Tellis v. Bombay Municipal Corporation, (1985) 3 SCC 545

Hint:

Article 21 → Right to life = includes environment (Subhash Kumar, MC Mehta cases).

Answer 1

The Correct Option is A

Step 1: Recalling case law.
Subhash Kumar held that Article 21 includes the right to pollution-free water and air as part of the right to life.
Step 2: Why others are incorrect.
Other cases deal with custodial death compensation, children’s rights, and right to livelihood—not pollution rights.
Step 3: Conclusion.
Thus, the correct case expanding Article 21 is Subhash Kumar.