Basic needs of man have traditionally been accepted to the three - food, clothing and shelter. The right to life is guaranteed in any civilized society. That would take within its sweep the right to food, the right to clothing, the right to decent environment and a reasonable accommodation to live in. The difference between the need of an animal and a human being for shelter has to be kept in view. For the animal it is the bare protection of the body; for a human being it has to be a suitable accommodation which would allow him to grow in every aspect physical, mental and intellectual. Id. at para. 9. Focusing on the right to a reasonable residence, which was at the heart of the case, the Court further explained, “a reasonable residence is an indispensable necessity for fulfilling the constitutional goal in the matter of development of man and should be taken as included in ‘life’ in Article 21[.]” Id. at para. 13. In Subhash Kumar v. State of Bihar, 1991 A.I.R. SC 420 (available at http://elaw.org/india.subhash.kumar.1991), petitioner sought an order to prohibit discharge of coal washing waste from coal mines into the Bokaro River. Although the Supreme Court of India ultimately dismissed the case because it was improperly filed as a public interest case, it nevertheless proclaimed that the right to life found in Article 21 of the Indian Constitution includes “the right of enjoyment of pollution free water and air for full enjoyment of life.” Id. at para. 7 Indian courts have continued to interpret the right to life to include substantive environmental rights in more recent cases, as well. See, for example, M.C. Mehta v. Union of India, Writ Petition No. 182 of 1996 (2000) (available at http://home.elaw.org/content/india-mc-mehta-v-union-india-wp-1821996-20000512beas-river-case); Forum, Prevention of Envn. & Sound Pollution v. Union of India , Civil Appeal No. 3735 of 2005 (2005) (available at http://home.elaw.org/content/forumprevention-envn-sound-pollution-v-union-india-ca-37352005-20051028); and Centre for Enviro. Law v. Union of India, Writ Petition No. 337 of 1995 (2013) (available at http://home.elaw.org/system/files/Centre_For_Envir._Law%2C_WwfI_vs_U_O_I_%26_Ors_on_15_April%2C_2013.PDF). 2. Pakistan The Supreme Court of Pakistan has also found that the right to life includes substantive environmental rights. In Shehla Zia v. WAPDA, P.L.D. 1994 S.C. 693 (available at http://elaw.org/pk.shehla.zia.1994), petitioners raised concerns about potential health risks from construction of high voltage transmission lines. In deciding the case, the Supreme Court of Pakistan noted, “Article 9 of the Constitution provides that no person shall be deprived of life or liberty save in accordance with the law. The word 'life' is very significant as it covers all facts of human existence. The word 'life' has not been defined in the Constitution but it does not mean nor can it be restricted only to the vegetative or 8