Option 1 states that it was held in the Maneka Gandhi vs. Union of India case that Article 19 and Article 21 are not watertight compartments. This means that the two articles are not completely separate and can overlap in certain situations. This statement is correct.

Option 2 states that it was held in the case that a law falling under Article 21 may not fulfill the requirements of Article 19. This statement is also correct, as the case established that even if a law is valid under Article 21 (right to life and personal liberty), it may still infringe on the fundamental rights guaranteed under Article 19 (right to freedom of speech, expression, etc.).

Option 3 states that a fair trial eliminates biases against the accused in the trial. This statement is a general statement about fair trials and does not specifically pertain to the Maneka Gandhi case. Therefore, it is not relevant to the question.

Option 4 states that the right to life under Article 21 does not include the right to die. This statement is the correct answer to the question. The Maneka Gandhi case did not specifically address the right to die or euthanasia, so this statement is not correct in the context of the case.

Therefore, option 4 is