Class#28 NOTES -MC Mehta Case

SUPREME COURT JUDGEMENTS SERIES
Class # 28
MC Mehta vs. Union of India (1987)
The M.C. Mehta vs. Union of India (1987) case is a major decision by India's Supreme Court
that focused on environmental protection, strict liability, and public interest litigation. The
case is important for emphasising corporate accountability in relation to environmental
degradation and public health protection.
Background:
1. Context: The case emerged as a result of a catastrophic incident involving an Oleum
gas leak at the Shriram Foods and Fertilisers Company in Delhi. The leak posed
serious health risks to the population of the surrounding districts, sparking public
outrage and legal action.
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2. M.C. Mehta, an environmental activist and lawyer, filed a public interest litigation
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(PIL) in the Supreme Court, demanding responsibility from the firm responsible for
the gas leak and remedial actions to preserve public health and environment. The
petition underlined the risks presented by hazardous businesses that lack basic
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safety procedures.
3. Legal Challenge: The PIL sought to establish the notion of strict liability for
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businesses that engage in hazardous activities and hold them liable for any harm
done to the people or the environment.
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Issues before the Court:
1. Strict Liability: The key legal challenge was whether the principle of strict liability
should be applied to businesses engaging in intrinsically harmful activity, implying
that they would be held accountable for any injury caused, regardless of
carelessness.
2. Right to a Healthy Environment: The Court had to evaluate how environmental
degradation affected the fundamental right to life guaranteed by Article 21 of the
Indian Constitution.
Supreme Court Ruling:

On December 8, 1987, the Supreme Court issued its decision.
Key Observations and Results:
1. Application of Strict Liability: The Supreme Court ruled that the principle of strict
liability applies in circumstances involving hazardous or intrinsically risky activity. The
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Court noted that enterprises involved in such operations must maintain the greatest
levels of safety and cannot avoid culpability by stating they took safeguards.
2. Right to a Healthy Environment: The Court emphasised that Article 21's right to life
includes the right to live in an environment free of pollution. The judgement
recognised the link between environmental conservation and citizens' fundamental
rights.
3. Corporate obligation: The Court determined that corporations had a social

obligation to protect the environment and public health. In this case, the Shriram
Foods and Fertilisers Company was held accountable for the gas leak and the
resulting harm to homeowners.
4. Remedial Measures: The Court ordered the corporation to take urgent remedial
action to address the health risks posed by the gas leak, as well as to implement
safety measures to prevent similar accidents in the future.
5. Public Interest Litigation: The decision emphasised the importance of public

interest litigation in resolving environmental challenges, allowing people and activists
to seek judicial action in matters impacting public health and the environment.
Impact of the Judgement:

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1. Environmental Law in India: The verdict had a profound impact on Indian
environmental law, establishing strict liability as a critical component of corporate
accountability for environmental harm.
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2. Strengthening Rights: The case reaffirmed the view that the right to a healthy
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environment is inextricably linked to the right to life, broadening the scope of

fundamental rights protected by the Constitution.
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3. Corporate Accountability: The decision established a precedent for holding

corporations liable for environmental damage, informing future lawsuits and rules
governing hazardous industries.
4. PIL Framework: The M.C.Mehta case demonstrated the importance of public

interest litigation in allowing access to justice for communities affected by
environmental degradation and corporate negligence.
5. Policy Reforms: As a result of the verdict, there has been an increase in awareness
and support for tougher laws controlling hazardous industries, as well as the need for
comprehensive environmental and public health safeguards.
Conclusion:
The M.C. Mehta vs. Union of India (1987) case is a seminal decision that influenced the
growth of environmental legislation and public health in India. The Supreme Court
established the concepts of strict liability and affirmed the right to a healthy environment as a
basic right, paving the way for corporate accountability and social responsibility. The case is
still used as a reference point in environmental law and the ongoing struggle for sustainable
development in India.
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Features of the Doctrine of Absolute Liability
1. No Exceptions or Defenses:
Unlike the rule of strict liability, the absolute liability doctrine does not allow for exceptions.
Industries cannot escape liability by arguing that the harm was caused by:
● Act of God (natural disasters like earthquakes or floods),

● Acts of a third party, or
● Victim’s own negligence.
2. Hazardous Enterprises:
● It applies to entities engaged in activities that pose a risk to public health or the
environment, such as chemical factories, oil refineries, and nuclear plants.
3. Compensation without Proof of Negligence:
● Victims are entitled to compensation regardless of whether the industry was

negligent or not. The focus is on the occurrence of harm, not on the fault of the
operator.
4. Public Interest:
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● The doctrine is based on the idea that industries operating in hazardous sectors must
prioritize public health and safety over profits.
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5. Deterrence:
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● It acts as a strong deterrent for industries, compelling them to adopt stringent safety
measures and ensure adherence to environmental and safety norms.
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Comparison: Strict Liability vs. Absolute Liability
Aspect Strict Liability Absolute Liability
Defenses Permits defenses like act of God No defenses allowed; liability is

Available or acts of third parties. absolute.
Nature of Applies to dangerous activities. Applies to ultra-hazardous or

Activity inherently dangerous activities.
Fault or Fault or negligence needs to be No need to prove fault or

Negligence established. negligence.
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Legal Basis and Evolution
● Origin:
The rule of strict liability was established in the English case of Rylands v. Fletcher
(1868). However, the Indian judiciary considered this outdated and unsuitable for
modern industrial contexts.
● Development in India:
The Supreme Court in the Oleum Gas Leak Case (1987) held that the strict liability
principle was inadequate for dealing with industries involved in hazardous activities.
The Court ruled that such industries must bear an absolute and non-delegable duty
to compensate victims, regardless of any intervening factors.
● Expanded Scope:
The doctrine has been extended to cases involving environmental harm, industrial
accidents, and other forms of public harm caused by hazardous activities.
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Class#28 NOTES -MC Mehta Case

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SUPREME COURT JUDGEMENTS SERIES

Issues before the Court:

Supreme Court Ruling:

Key Observations and Results:

3. Corporate obligation: The Court determined that corporations had a social

5. Public Interest Litigation: The decision emphasised the importance of public

Impact of the Judgement:

environment is inextricably linked to the right to life, broadening the scope of

3. Corporate Accountability: The decision established a precedent for holding

4. PIL Framework: The M.C.Mehta case demonstrated the importance of public

● Act of God (natural disasters like earthquakes or floods),

3. Compensation without Proof of Negligence:

● Victims are entitled to compensation regardless of whether the industry was

Comparison: Strict Liability vs. Absolute Liability

Aspect Strict Liability Absolute Liability

Defenses Permits defenses like act of God No defenses allowed; liability is

Nature of Applies to dangerous activities. Applies to ultra-hazardous or

Fault or Fault or negligence needs to be No need to prove fault or

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