M.C Mehta vs Union of India & Ors
M.C. Mehta vs. Union of India & Ors (Oleum Gas Leak Case, 1987)
1. Court:
Supreme Court of India
2. Citation:
1987 SCR (1) 819; AIR 1987 SC 1086
3. Background / Facts:
This case arose out of a gas leak incident involving Shriram Foods and Fertilizers Industries in Delhi.
The plant released oleum gas (fuming sulfuric acid) into the atmosphere.
This caused serious health hazards to people living in nearby areas, including breathing difficulties and other ailments.
M.C. Mehta, a prominent public interest lawyer, filed a Public Interest Litigation (PIL) in the Supreme Court seeking action against the company and measures to prevent such incidents.
4. Issues:
Whether the hazardous enterprise could be held liable for the consequences of the gas leak.
What measures should be taken to regulate hazardous industries to prevent environmental harm.
Whether the concept of absolute liability applies to industries engaged in hazardous activities.
What should be the quantum and nature of compensation payable to victims.
5. Supreme Court’s Judgment:
The Court recognized the principle of absolute liability for hazardous industries.
Held that enterprises engaged in hazardous or inherently dangerous activities owe an absolute and non-delegable duty to ensure safety.
They are liable to compensate for any harm caused, regardless of any negligence or fault.
Distinguished from the traditional strict liability rule laid down in Rylands v. Fletcher (English law) by making the liability absolute and without exceptions.
The Court ordered Shriram to pay compensation to the victims.
It directed the government to introduce strict environmental standards and regulations to control such industries.
Emphasized the precautionary principle and polluter pays principle as foundational to environmental jurisprudence in India.
6. Legal Principles Established:
Absolute Liability:
An enterprise engaged in hazardous activities is absolutely liable for any harm caused, with no exceptions such as acts of God, third-party acts, or contributory negligence.
Precautionary Principle:
The polluter must take all necessary measures to prevent environmental harm even if scientific certainty about harm is not established.
Polluter Pays Principle:
The polluting party must bear the cost of pollution and remedy the damage caused.
Public Trust Doctrine:
The government has a duty to protect natural resources for the benefit of the public.
7. Comparison with Other Case Law:
| Case | Principle |
|---|---|
| Rylands v. Fletcher (1868) | Strict liability but with exceptions like Act of God, plaintiff’s own fault, third-party acts. |
| Vellore Citizens Welfare Forum v. Union of India (1996) | Affirmed precautionary and polluter pays principles. |
| Indian Council for Enviro-Legal Action v. Union of India (1996) | Expanded on absolute liability and compensation for hazardous industries. |
8. Impact and Significance:
This case was a milestone in Indian environmental law.
It marked the evolution of tort law concerning environmental damage and industrial hazards.
Helped establish environmental protection as a constitutional duty under Articles 48-A and 51-A(g) of the Constitution.
Paved the way for stricter environmental regulation and judicial activism in environmental matters.
Set a precedent for Public Interest Litigation (PIL) as an effective tool for environmental protection.
9. Summary Table:
| Aspect | Details |
|---|---|
| Case Name | M.C. Mehta vs. Union of India & Ors (Oleum Gas Leak Case) |
| Court | Supreme Court of India |
| Year | 1987 |
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