SUBHASH KUMAR vs STATE OF BIHAR .

The Supreme Court dismissed a public interest litigation alleging that West Bokaro Collieries and Tata Iron and Steel Company were polluting the river Bokaro, holding that the petition lacked substantiation and was motivated by personal interest rather than genuine public concern. The Court emphasized that Article 21 of the Constitution guarantees the right to a pollution-free environment as part of the right to life, but reiterated that public interest litigation should not be misused for personal grievances. The Court upheld the actions of the Bihar State Pollution Control Board and the compliance of the companies with the Water (Prevention and Control of Pollution) Act, 1974, specifically Sections 25 and 26.