MeetJustice P.N. Bhagwati and his Notable Judicial decisions
- ByPravleen Kaur --
- 17 Jun 2025 --
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Justice Prafullachandra Natwarlal Bhagwati (1921–2017) was the 17th Chief Justice of India, serving from July 12, 1985, to December 20, 1986. Renowned as a pioneer of judicial activism, he fundamentally transformed Indian jurisprudence by introducing the concepts of Public Interest Litigation (PIL) and absolute liability, making justice more accessible to the marginalized and vulnerable sections of society.
Born in Gujarat, Bhagwati was the son of Justice Natwarlal H. Bhagwati, himself a Supreme Court judge. After earning a Mathematics (Hons.) degree from Bombay University and a law degree from Government Law College, Mumbai, he began his legal career at the Bombay High Court. He was appointed a judge of the Gujarat High Court in 1960, became its Chief Justice in 1967, and joined the Supreme Court in 1973. He became Chief Justice of India in 1985.
Landmark Judgments and Contributions
1. Public Interest Litigation (PIL):
Justice Bhagwati is best remembered for institutionalizing PIL, allowing any individual or group to approach the courts on behalf of those whose rights were being violated, even if they were not directly affected. This innovation democratized access to justice and empowered the judiciary to address issues of social injustice, environmental protection, and human rights.
2. Absolute Liability Principle:
In the landmark Oleum Gas Leak case (M.C. Mehta v. Union of India, 1986), Bhagwati established the doctrine of absolute liability for industries engaged in hazardous activities. This meant such enterprises would be strictly liable for any harm caused, without exceptions, setting a higher standard than the traditional “strict liability” rule. This judgment revolutionized environmental law and corporate accountability in India.
3. Expansion of Fundamental Rights:
Bhagwati’s expansive interpretation of the Constitution led to the broadening of fundamental rights, particularly in relation to Article 21 (right to life and personal liberty). He emphasized that these rights must be interpreted liberally to serve the needs of a just and equitable society.
4. Judicial Activism and Social Justice:
For Bhagwati, judicial review was a tool for social change. He believed in using the law to achieve social justice, often “breathing life into law” to cover areas previously neglected by the courts. His judgments reflected a commitment to the rights of the poor, women, children, and other marginalized groups.
Legacy
Justice P.N. Bhagwati authored 342 judgments and sat on 820 benches during his Supreme Court tenure. He was awarded the Padma Vibhushan in 2007 for his contributions to public affairs. His legacy endures in the form of a more accessible, responsive, and socially conscious judiciary, making him one of the most influential figures in the history of Indian law.
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