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Environment and life are interrelated. In which of the following cases Supreme Court did not interpret Article 21 to include environment in its ambit
Charan Lal Sahu Case (1991)
Narmada Dams (Narmada Bachao Andolan vs. Union of India AIR 1999 SC 3345)
WWF vs. Union of India,
Maneka Gandhi Vs Union of India (AIR 1978 SC 597)
In Maneka Gandhi Vs Union of India (AIR 1978 SC 597) case Supreme Court did not interpret Article 21 to include environment in its ambit. In Maneka Gandhi vs Union of India case (1978) SC held that – ‘Procedure established by law’ within the meaning of article 21 must be ‘right and just and fair’ and ‘not arbitrary, fanciful or oppressive’ otherwise, it would be no procedure at all and the requirement of Article 21 would not be satisfied. Thus, the ‘procedure established by law’ has acquired the same significance in India as the ‘due process of law’ clause in America.
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