Other implicit rights have been derived from the Constitutional right to life, including the right to seek and be engaged in lawful and gainful employment and receive benefits that society has to offer its members. Thus, it should also include the right to live in a reasonably healthy and pollutant-free environment.
Chief Justice Arifin also requested that Justice Tan Sri Richard Malanjum spearhead the drafting and introduction of a set of Environmental Rules of Court to encourage and support the practice of environmental law in courts. The environment and its preservation are integral to sustaining a diverse and successful culture and society. Other countries, including India and the Philippines, have made strides in environmental law and enforcement, and Justice Arifin urges Malaysia to do the same.