A savyabhicāra hetu is one that is found in cases where the sādhya is present and also in cases where the sādhya is absent, making the middle term irregular and unreliable. Water is present in many lakes with fish and also in various water bodies without fish, so the presence of water does not uniformly indicate fish. The hetu “having water” thus admits counterinstances and fails to secure the conclusion.
Option A:
Option A uses “being a quality” as reason for “being produced,” which is debated but not a simple case of the same hetu occurring with and without the sādhya in an obvious way.
Option B:
Option B is the standard valid inference where smoke is treated as a reliable sign of fire; the hetu is not savyabhicāra in the classical example.
Option C:
Option C also shows a too broad reason (“having horns”), since many non cows have horns; it is another kind of anaikāntika style defect, though the water–fish case in D shows the irregularity even more clearly.
Option D:
Option D aptly shows a reason that is too broad, appearing in many cases lacking the intended conclusion, which is the hallmark of savyabhicāra.
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