Its d the cell wall. The plant cell contains a cell wall that is absent in a animal cell.
Due to a law being a predicted sort of event that is bound to happen every time, a pattern, we can say that since the cell theory is a pattern instead of a possible explanation, it can be a law. However, since we don't have an accurate explanation to the part which claims that they all come from pre-existing cells, it is a theory, we don't have enough information to confirm that the theory is a solid fact, therefore, we can't confirm that it is a law.
I think is D i hope this helps
The DNA region is easily accessible
^^^^^^^^^^^^