M. C. Mehta vs. Union of India (Oleum Gas Leak Case, 1986)

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Case Snapshot

Citation: AIR 1987 SC 965; 1987 SCR (1) 819
Court: Supreme Court of India
Date of Judgment: 20 December 1986 (delivered in 1987)
Bench: Chief Justice P. N. Bhagwati, Justices G.L. Misra, Rangnath Oza, M.M. Dutt, K.N. Singh

Facts of the Case

• In December 1985, a leak of Oleum gas occurred from one of the units of Shriram Food and Fertilizers Ltd., located in Delhi.
• The leak led to the death of an advocate in the Tis Hazari Court and caused severe health problems to many people in the surrounding areas.
• Around the same time, India was still recovering from the Bhopal Gas Tragedy (1984), which heightened concerns about industrial safety.
• Public Interest Litigator M. C. Mehta filed a petition under Article 32 of the Constitution, seeking accountability and strict liability for hazardous industries operating in densely populated areas.

Legal Issues of the Case

1. Whether the principle of strict liability (as in Rylands v. Fletcher) was sufficient to deal with industrial hazards in India.
2. Whether hazardous industries located in thickly populated areas could be allowed to operate without absolute responsibility for any harm caused.
3. Whether Article 21 (Right to Life) included the right to a safe and healthy environment.

Arguments of the Case

Petitioner (M. C. Mehta)

• The leakage demonstrated the serious threat posed by hazardous industries to human life and the environment.
• The doctrine of strict liability was inadequate since it allowed exceptions (like act of God, plaintiff’s fault, etc.).
• Industries engaged in dangerous activities must be held absolutely liable for any damage caused, regardless of fault.

Respondent (Shriram Industries & Union of India)

• Argued that the accident was unforeseen and not due to negligence.
• Claimed that complete liability without exceptions would discourage industrial growth.
• Suggested that existing laws and compensation mechanisms were sufficient.

Judgment of the Court

• The Supreme Court of India, led by Justice P. N. Bhagwati, laid down the landmark doctrine of Absolute Liability.
• The Court ruled that an enterprise engaged in hazardous or inherently dangerous activities is absolutely liable to compensate all those affected by an accident, and no exceptions (like those in strict liability) would apply.
• The Court also emphasized that Article 21 includes the right to live in a safe environment.
• It directed hazardous industries to adopt the highest safety standards and evolve a mechanism for immediate relief and compensation.

Ratio Decidendi

• Introduced the doctrine of Absolute Liability in Indian law, which is stricter than the traditional English rule of Strict Liability.
• Hazardous industries have a non-delegable duty to ensure community safety and cannot escape liability under any circumstances.

Legal Significance

1. Landmark in Environmental Jurisprudence – The case became the foundation of Indian environmental law.
2. Expanded Article 21 – Interpreted the right to life as including the right to a clean and healthy environment.
3. Polluter Pays Principle – Strengthened the idea that industries must bear the cost of environmental damage.
4. Shift from Strict to Absolute Liability – A uniquely Indian doctrine tailored to protect citizens against industrial risks.

The M. C. Mehta vs. Union of India (Oleum Gas Leak Case, 1986) marked a turning point in Indian legal history. By establishing the principle of absolute liability, the Supreme Court ensured that industries engaging in dangerous activities would be held fully responsible for their impact on human life and the environment. The case not only safeguarded the constitutional right to life but also laid the groundwork for stronger environmental governance in India.