B. The right to life inherently incorporates many of the other rights raised in the petition. Courts around the world, as well as international and regional human rights bodies, have determined the right to life encompasses the right to a healthy environment (or its equivalent) and other rights that are raised in the petition. 1. India For decades, courts in India have recognized the right to life inherently includes other rights, including the right to live in a healthy environment. For example, in T. Damodhar Rao v. Municipal Corp. of Hyderabad, 1987 A.I.R (AP) 171 (available at https://indiankanoon.org/doc/205063/), the High Court of Andhra Pradesh considered whether a company (or its transferee) that legally owned land within an area designated by the city for recreation could build residential units on the land. The court held that constructing houses in the designated recreational area was contrary to the right to life protected under Article 21 of India's Constitution. The court issued a mandamus to prohibit further construction and directed government authorities to demolish any structures that might have been built during the litigation. The court explained: Examining the matter from the . . . constitutional point of view, it would be reasonable to hold that the enjoyment of life and its attainment and fulfilment guaranteed by Art. 21 of the Constitution embraces the protection and preservation of nature's gifts without [which] life cannot be enjoyed. There can be no reason why practice of violent extinguishment of life alone should be regarded as violative of Art. 21 of the Constitution. The slow poisoning by the polluted atmosphere caused by environmental pollution and spoilation should also be regarded as amounting to violation of Art. 21 of the Constitution. . . . It, therefore, becomes the legitimate duty of the Courts as the enforcing organs of Constitutional objectives to forbid all action of the State and the citizen from upsetting the environmental balance. . . . The object of reserving certain area as a recreational zone would be utterly defeated if private owners of the land in that area are permitted to build residential houses. It must, therefore, be held that the attempt of [the company and its transferee] to build houses in this area is contrary to law and also contrary to Art. 21 of the Constitution. Id. at paras. 24-25. In 1990, the Supreme Court of India recognized that rights to a decent environment, food, clothing, and reasonable accommodation are all included in the right to life. See Shantistar Builders v. Narayan Khimalal Totame [1990] 1 SCC 520 (available at: http://elaw.org/india.shantistar.1990). The Supreme Court declared: 7