On 9 January 1991, a Division Bench of the Supreme Court — Justices K.N. Singh and N.D. Ojha — articulated the right to enjoyment of pollution-free water and air as part of the right to life under Article 21, and held that PIL standing in environmental matters does not require a personal-injury showing. On the facts the petition was dismissed as not bona fide and ₹5,000 costs imposed, but the legal principles — though technically obiter — have been treated as authoritative in every subsequent environmental Article 21 case.