M.C. Mehta v. Union of India (1987) | Oleum Gas Leak Case & Absolute Liability
⚖️ Landmark Case Law Summary
Subject: Law of Torts / Environmental Law
M.C. Mehta & Anr. vs. Union of India & Ors.
Citation: 1987 SCR (1) 819; AIR 1987 SC 1086
🔍 Facts of the Case
In December 1985, a major leakage of Oleum Gas occurred from one of the units of Shriram Food and Fertilisers in Delhi. This leakage resulted in the death of one advocate and several others were hospitalised. The petition was filed by activist lawyer M.C. Mehta under Article 32 of the Constitution, seeking the closure of the plant as it was located in a densely populated area.
❓ Key Issues
- Whether a private corporation can be held liable for hazardous activities under Article 32?
- What should be the measure of liability for industries engaged in inherently dangerous activities?
🏛️ The Judgement
The Supreme Court, led by Justice P.N. Bhagwati, laid down a new principle of liability. The court departed from the English rule of Strict Liability (Rylands v. Fletcher) and established the Doctrine of Absolute Liability.
Principle: Absolute Liability
"An enterprise which is engaged in a hazardous or inherently dangerous industry which poses a potential threat to the health and safety of the persons working in the factory and residing in the surrounding areas owes an absolute and non-delegable duty to the community to ensure that no harm results to anyone."
✅ Key Takeaways for Students
- No Exceptions: Unlike Strict Liability, Absolute Liability has no exceptions (like Act of God or Sabotage).
- Deep Pocket Theory: The compensation must be correlated to the magnitude and capacity of the enterprise (the richer the company, the higher the fine).
- Public Interest: This case strengthened the Right to Life under Article 21.
For more Case Law Summaries, visit the Case Law Library.