The most significant achievement of modern law in India is the constitutionalization of environmental problems by the Supreme Court.” Discuss this statement with the help of relevant case laws.

Environment and life are interrelated. Thus, the quality of the environment is undeniably related to our enjoyment of the right to life under Article 21. Supreme Court intervention in environmental problems can be clubbed as:

Incorporation of environmental problems into the ambit of Fundamental right.

• Shubash Kumar VS State of Bihar:- “Right to live includes the right to enjoyment of pollution free water and air for full enjoyment of life.” 
• Re: Noise Pollution vs Unknown:- The noise level at the boundary of the public place, where loudspeaker or public address system or any other noise source is being used shall not exceed 10 dB(A) above the ambient noise standards for the area or 75 dB(A) whichever is lower.

Merging of DPSP and FR.

• Sachidanand Pandey V. State of W.B. Chinnappa Reddy J:- SC referred to Article 48A of the Constitution which enshrined the directive principle to protect and improve the environment.

Incorporation of international norms of 3rd generation collective rights of sustainable development into Indian law.

• Samit Mehta v. Union of India:- The Court reaffirmed the “Precautionary Principle” and “Polluter Pays Principle” and also recognized Right to clean environment as a fundamental right under Article 21.

The Supreme Court making creative interpretation which led to the creation of new rights. As under Article 21, this court has created new rights including the right to health and pollution free environment.