Summary of Recent judgment

Case: M.C. Mehta & Anr. v Union of India & Ors



Date of Order / Judgment: 22nd August, 2024

The Matter Heard by Bench: Justice P.N. Bhagwati, Justice Ranganath Misra, Justice G.L. Oza, Justice M.M.Dutt, Justice K.N. Singh

Background

This case arises from the catastrophic gas leak that occurred at the Shriram Food and Fertiliser Industries in Delhi on December 4-6, 1985, resulting in the death of several people and injuries to many. The case was brought to the Supreme Court by M.C. Mehta, a renowned environmental activist and lawyer, as a Public Interest Litigation (PIL) under Article 32 of the Indian Constitution, seeking compensation for the victims and stronger environmental protections. This case brought attention to the issue of industrial safety and environmental hazards posed by chemical industries.

Issues
  • 1. What should be the extent of liability of enterprises handling the hazardous industries.
  • 2. Whether the safety measures in place at Shriram Industries were adequate and complied with relevant regulations.
  • 3. What should be the quantum and mechanism for compensating the victims of the gas leak?
Observation

The Court observed that in cases involving hazardous or inherently dangerous industries, strict liability principles were insufficient, as they allowed for certain exceptions like "acts of God." The Court highlighted the necessity of a more stringent legal framework to deal with such industries in the interest of public welfare and environmental protection. It further emphasized that industries engaged in dangerous activities owe an absolute duty to ensure the safety of the community. The Court rejected the defense of "no-fault" in such incidents, stating that companies profiting from hazardous activities must bear the responsibility for any damage caused by such activities, regardless of whether they took reasonable precautions.

Decision

The Supreme Court adopted the doctrine of absolute liability, ruling that companies involved in hazardous industries cannot plead defenses like lack of negligence or act of God. The Court held that Shriram Industries was absolutely liable for the gas leak incident and must compensate the victims.

The Court also ordered the closure of the caustic chlorine unit of Shriram Industries until further safety mechanisms were installed to prevent future accidents. It further directed that stronger environmental safeguards and industrial safety measures must be implemented in all industries posing environmental hazards, and governmental agencies must ensure compliance through proper inspections and regulations.