Case Law On Factory Fire And Structural Collapse Prosecutions

11 Oct 2025 --
0 Comments

1. Kedar Nath Singh v. State of Bihar (1977) – Factory Negligence Context

Facts:
Although this case primarily dealt with general criminal liability, it is often cited in industrial accident cases. In an industrial plant, unsafe practices led to accidental deaths.

Legal Issues:

Whether criminal negligence (Section 304A IPC) can be applied to industrial deaths.

The distinction between rash/negligent acts versus intentional acts.

Court Reasoning:

The Supreme Court clarified that for criminal negligence leading to death, the act must be grossly negligent or reckless, beyond mere carelessness.

Negligence must be foreseeable and directly linked to the death.

Outcome:

Liability under Section 304A IPC was confirmed in principle for industrial deaths due to unsafe practices.

Significance:
This case forms a foundation for prosecuting factory owners or supervisors in cases of fire or structural collapse when negligence causes death.

2. Plastics Factory Fire & Building Collapse, Ludhiana (2017)

Facts:
A plastics factory in Ludhiana caught fire, and the building partially collapsed, killing 16 people including workers and fire‑fighters. The investigation found a lack of firefighting equipment and improper storage of chemicals.

Legal Issues:

Whether the charges should be framed under Section 304 IPC (culpable homicide) or Section 304A IPC (death by negligence).

The extent of criminal liability for owners.

Court Reasoning:

The court held that there was negligence, but no evidence of intent to cause death.

Charges under Section 304 were inappropriate; Section 304A was more applicable.

Outcome:

Charges under Section 304A IPC were directed.

Regulatory actions under the Factories Act were also recommended.

Significance:
Shows the importance of differentiating between gross negligence and intent, and highlights the role of regulatory compliance in prosecution.

3. Baldia Town Garments Factory Fire, Karachi (Pakistan, 2012)

Facts:
A multi-story garment factory fire killed over 260 workers. Locked exits and poor safety measures worsened the tragedy. Investigation found it was caused by arson linked to extortion.

Legal Issues:

Distinction between accidental fire versus intentional arson.

Liability of factory owners, supervisors, and political actors.

Court Reasoning:

The arsonists were held responsible for intentional deaths.

Factory owners’ negligence in safety measures contributed to the scale of the tragedy.

Outcome:

Two arsonists received death sentences; life imprisonment for some employees; others acquitted.

Significance:

Mass casualty industrial fires can attract the harshest penalties, especially when combined with criminal intent.

Highlights the interaction between intentional criminal acts and negligent management.

4. Chemical Factory Boiler Explosion, Vadodara (Gujarat, 2018)

Facts:
A chemical factory boiler exploded, killing four people, including children present near the factory, and injuring 11. Unsafe storage of chemicals and proximity of non-workers exacerbated the harm.

Legal Issues:

Liability of directors under Sections 304 and 308 IPC.

Standard for “gross negligence” leading to death.

Court Reasoning:

Directors were found negligent because deaths were foreseeable due to unsafe operations.

Proximity of family members to dangerous operations demonstrated disregard for safety.

Outcome:

Directors arrested and charged; proceedings under IPC 304 and 308 initiated.

Significance:

Demonstrates that even directors not directly handling machinery can be criminally liable.

Highlights foreseeability and risk management in industrial prosecutions.

5. Firecrackers Factory Fire, Bawana, Delhi (2018)

Facts:
A fire in an illegal firecracker factory killed 17 workers. Investigations revealed inadequate exits and lack of safety equipment.

Legal Issues:

Owners’ liability under IPC and Explosives Act.

Compensation for victims’ families under Employees’ Compensation Act.

Court Reasoning:

Owner’s failure to ensure worker safety constituted criminal negligence.

Court emphasised protection of life of vulnerable workers.

Outcome:

Owner ordered to deposit ₹34 lakh for compensation.

Criminal proceedings initiated under IPC 304A and Explosives Act.

Significance:

Shows interplay between criminal liability and compensation.

Highlights regulatory gaps in illegal factories and the courts’ role in interim relief.

6. Delhi Garments Factory Fire, Anaj Mandi (2019)

Facts:
A fire killed 43 labourers in an illegal factory producing plastic items. Exits were blocked, and structural design was unsafe.

Legal Issues:

Owners’ liability for illegal operations.

Liability of municipal authorities for allowing unsafe conditions.

Court Reasoning:

Owners held responsible for unsafe working conditions.

Municipal authorities’ failure to monitor or enforce safety contributed to risk.

Outcome:

FIR filed against owners; investigation into regulatory negligence ongoing.

Significance:

Shows that criminal liability can extend to multiple actors: owners, supervisors, regulators.

Emphasises that unsafe, unauthorized operations carry severe legal consequences.

7. Supervisor Held Liable, Delhi Garments Factory Fire (1997)

Facts:
A fire caused death of three workers due to lack of fire extinguishers and safety measures. The mid-level supervisor was in charge of operations.

Legal Issues:

Can a supervisor, not the owner, be criminally liable for industrial deaths?

Court Reasoning:

Supervisor had a duty of care to ensure safe environment.

Failure to provide safety equipment made him criminally negligent.

Outcome:

Convicted under Sections 304A and 337 IPC; sentenced to two years’ imprisonment.

Significance:

Liability is not limited to owners or directors.

Mid-level personnel can be prosecuted for negligence if safety duties are ignored.