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Why is the cell theory still referred to as a theory and not as a law?

Biology
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A. Cell theory will be referred to as a law once it is 100% certain that it is proven true.
B. Cell theory is not referred to as a law because scientists are not sure that it is accurate.
C. Cell theory will remain a theory because it is the most powerful implantation scientists have to offer.

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Other answers:

The first thing we ought to remember is that theories never become laws. And laws never become theories. So that means that A isn't the answer. I don't think B sounds right either. Because every new discovery in biology starts with Cell Theory. I'm sure most biologists believe in the accuracy of Cell Theory. And that only leaves us with C.

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