Also notable is the case of "Subhash Kumar v. State of Bihar", where a discharge of sludge from the washeries into the Bokaro River was petitioned against by way of public interest litigation. The courts found that the right to life, as protected by Article 21 of the Constitution of India, included the right to enjoy pollution-free water. The case failed upon the facts and it was held that the petition had been filed not in any public interest but for the petitioner's personal interest and therefore a continuation of litigation would amount to an abuse of process.