The correct option is (a).
Explanation
Article 21 of the Indian Constitution guarantees the Right to Life and Personal Liberty. Through judicial activism and liberal interpretation, the Supreme Court has expanded the scope of Article 21 to include various implied rights essential for a dignified life, such as the right to livelihood, clean environment, and health.
Statement-wise Analysis:
- Statement 1 is Correct: In the landmark case of Olga Tellis vs. Bombay Municipal Corporation (1985), the Supreme Court held that the Right to Livelihood is an integral part of the Right to Life under Article 21. The Court reasoned that no person can live without the means of living, i.e., the means of livelihood. If the right to livelihood is not treated as a part of the constitutional right to life, the easiest way of depriving a person of his right to life would be to deprive him of his means of livelihood.
- Statement 2 is Incorrect: The case of Subhash Kumar vs. State of Bihar (1991) is related to the Right to a Pollution-Free Environment. The Supreme Court ruled that the Right to Life under Article 21 includes the right to the enjoyment of pollution-free water and air for the full enjoyment of life. The Right to Education was primarily established through cases like Mohini Jain (1992) and Unni Krishnan (1993), and later codified by the 86th Constitutional Amendment Act.
- Statement 3 is Incorrect: The case of Paschim Banga Khet Mazdoor Samiti vs. State of West Bengal (1996) is related to the Right to Health and timely medical treatment. The Supreme Court held that the failure of government hospitals to provide timely medical treatment to a person in need of emergency aid amounts to a violation of the Right to Life under Article 21. The Right to Shelter is associated with cases such as Chameli Singh vs. State of U.P. (1996).
Key Takeaway:
Article 21 is an umbrella provision that encompasses implied rights. Olga Tellis relates to Livelihood, Subhash Kumar relates to Environment, and Paschim Banga Khet Mazdoor Samiti relates to Health/Emergency Medical Aid.