animal life or mere existence from conception to death. Life includes all such amenities and facilities which a person born in a free country is entitled to enjoy with dignity, legally and constitutionally. For the purposes of present controversy suffice it to say that a person is entitled to protection of law from being exposed to hazards of electromagnetic fields or any other such hazards which may be due to installation and construction of any grid station, any factory, power station or such like installations.” Id. at para. 12. The Court continued on to find, “The Constitution guarantees dignity of man and also right to life under Article 9 and if both are read together, question will arise whether a person can be said to have dignity of man if his right to life is below bare necessity like without proper food, clothing, shelter, education, health care, clean atmosphere and unpolluted environment. Such questions will arise for consideration which can be dilated upon in more detail in a proper proceeding involving such specific questions.” Id. at para. 14. In West Pakistan Salt Miners Labour Union v. Industries and Mineral Development, 1994 S.C.M.R. 2061 (available at: https://www.elaw.org/system/files/SC-1994-Salt-Miners-v.-Director-Industries-andMineral-Development.pdf), the Supreme Court of Pakistan determined the right to life includes the right to clean water. Interpreting Article 9 of Pakistan’s Constitution, the Court stated, “the right to have water free pollution and contamination is [a] right to life itself. . . . The right to have unpolluted water is the right to every person wherever he lives.” The Court explained, “[t]he petitioners' demand here is the barest minimum. Water has been considered source of life in this world. Without water there can be no life. . . . Therefore, water, which is necessary for existence of life, if polluted, or contaminated, will cause serious threat to human existence. In such a situation, persons exposed to such danger are entitled to claim that their fundamental right of life guaranteed to them by the Constitution has been violated and there is a case for enforcement of fundamental rights by giving directions 'or passing any orders to restrain the parties and authorities from committing such violation.’” 3. Bangladesh Articles 31 and 32 of Bangladesh’s constitution protect the right to life as a fundamental right. In Mohiuddin Farooque v. Bangladesh [1997] 17 B.L.D. (A.D.) 1 (available at https://elaw.org/bd.farooque.FAP.1996), the Supreme Court of Bangladesh determined the protection of the right to life “encompasses within its ambit, the protection and preservation of the environment, ecological balance free from pollution of air and water, and sanitation without which life can hardly be enjoyed. Any act or omission contrary thereto will be violative of the said right to life.” 4. Nigeria Sections 33 and 34 of Nigeria’s Constitution protect the fundamental right to life and dignity. In Gbemre v. Shell Petroleum Dev. Co. Nigeria Ltd. [2005] AHRLR 151 (available at https://www.informea.org/sites/default/files/court-decisions/COU- 9