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Bombay High Court, in its recent judgement in Milun Suryajani v. Pune Municipal Commissioner decided on 23.12.2015, by the bench consisting of A.S. Oka and Revati Mohite Dere, JJ., directed all the Municipal Corporations to set up toilets and urinal facilities for women walking on the streets. The hon’ble Court emphasized on the relation between health of the citizens and toilets and stated that the right conferred under Art. 21 will be meaningless if clean and hygienic toilets are not provided to women walking on streets. The petitioners contended that there are only 180 toilets for 17 lakh women residing in Pune Municipal Corporation area and that there was no efforts being made by the Pune Municipal Corporation to carry out its public duties. The court observed that right to clean toilets also spring from Art. 47 and Art. 48-A of the constitution which imposes duty on the state for welfare of its citizens. The Court directed the municipal corporations to form a committee within 4 weeks to work on the guidelines issued by court for construction of toilets, urinals and privies.

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