Author: Rithanya, The Central Law College
TABLE OF CONTENTS
ABSTRACT
INTRODUCTION
BACKGROUND OF THE CASE
LEGAL ISSUES OF THE CASE
JUDGEMENT
ANALYSIS OF JUDGEMENT
CONCLUSION
FAQS
ABSTRACT
M.C. Mehta v. Shri Ram Food and Fertilizer Industries stands as a landmark case law by establishing the principle of “absolute liability” for hazardous industries in India. This case arose following the tragic Oleum gas leak in 1985, which caused severe harm to human lives and the environment. The Supreme Court of India, in its ruling, held Shri Ram Food and Fertilizer Industries liable for the incident and directed compensation to the affected parties. Recognizing the inherent risks posed by hazardous industries, the Court introduced stringent conditions for their operation to safeguard public health and environmental sustainability. At the same time, the Court acknowledged the socio-economic ramifications of a blanket ban on industries of this nature. It highlighted that shutting down such enterprises could impede national development and disrupt the livelihoods of over 4,000 workers. To balance industrial development with environmental protection, the Court meticulously crafted conditions for the safe functioning of such industries, ensuring that economic progress and environmental safety could coexist. This comprehensive judgment underscores the Supreme Court’s adept consideration of legal, social, and economic dimensions, demonstrating a commitment to environmental justice while fostering national development. It marks a significant evolution in liability principles, enhancing public interest litigation and embedding environmental protection within the framework of Article 21 of the Constitution. The case serves as a cornerstone for future discourse on sustainable industrial practices in India.
INTRODUCTION
Shriram Foods and fertilizers industry engaged with multiple units, manufacturing sodium hydroxide, chlorine, super phosphate, oleum etc. All units were located in densely populated areas like Shastri nagar, Ashok vihar, Trinagar and near the outskirts of Delhi which covered approximately 76 acres of land. On 6th December 1985, the district magistrate of Delhi ordered this industry to withdraw chemicals from manufacturing hazardous chemicals under section 131(1) of CrPC. This order was challenged before the court and MC Mehta approached the Apex court to seek compensatory relief of the damages incurred through filing of PIL. However, the Shriram case stands out as the Supreme Court not only held the industry entirely responsible for the harm caused but also introduced the Absolute Liability Principle. This new rule established that industries dealing with hazardous substances are completely accountable for any harm caused, without exceptions. Recognizing the socio-economic importance of such industries, the Court permitted their operation under stringent conditions, balancing public safety, environmental protection, and national development. This judgment remains a cornerstone in India’s environmental jurisprudence, transforming liability standards while addressing industrial risks and societal needs.
BACKGROUND OF THE CASE
A Writ petition was filed by M.C Mehta seeking to closure of Shriram Foods and fertilizers industry, which releases hazardous chemicals and gases located in Kiritinagar, Delhi. Oleum gas got leaked from Shriram industry on 4th – 6th December 1985. While the writ petition was still pending before the court. This incident happened after a year from Bhopal gas tragedy. Due to this Oleum gas leakage, large population suffered from the health and respiratory issues. M.C Mehta filed writ petition under Article 32 of the constitution before the Supreme Court to give effect to the Article 21 of the Indian Constitution, seeking to order to closure of this hazardous industry and to pay compensation to the victims.
LEGAL ISSUES OF THE CASE
Three judge bench permitted the Shriram food fertilizer to restart its power plant within some specific conditions. However, on the matter relating to compensation, a larger bench of five judges has been appointed for the constitutional issues. The issues are as follows:
The first issue was about scope and ambit of jurisdiction of the Supreme Court under Article 32 of the Indian Constitution.
Secondly, Whether the Shriram industry fall under Article 12 of Indian Constitution as a state?
Third issue was, does the rule in Ryland v. Fletcher could be applied in this case?
JUDGEMENT
On 12th of December 1986, five judge bench of Supreme Court headed by Chief Justice Bhagawati delivered the judgment in the favour of the petitioner. Petitioner argued that the nature of the activity of the industry was dangerous to the lives of people and hence the industry must be made absolutely liable. Operation of such industry near the areas of cities violated Article 21 of the Indian Constitution and claimed that the compensation should be paid to all the victims as the industry had failed to take safety measures. Chief Justice also showed his deep concern for the safety of Delhi people from leakage of such hazardous gas. He was of the opinion that the policy of total ban on hazardous industry cannot be adopted as it helps in accelerating economic growth. The Supreme Court observed that the power under Article 32 is not only confined to the preventive measures but also extends to providing the remedial measures when rights are already violated. The court also stated that it entertains the compensation claim under Article 32 of Constitution only in some exceptional cases. For the second issue, the court relied on the R.D. Shetty’s case, Ajay Hasia v. Khalid Mujib, thus the court regarded industry as a state and granted relief under Article 21 of the Indian Constitution. In deciding the liability of hazardous industries, the rule laid down in the Ryland v. Fletcher was applied. Many industry take a defence of act of god or act of stranger, so Supreme Court introduced absolute liability. Which stated an industry engaged in hazardous industry which possesses a potential danger to health and safety of the people employed in industry and even if there is no fault on the part of industrial management, the industry could be held as absolutely liable. Anything danger happens then such industry cannot escape from the liability.
ANALYSIS OF JUDGEMENT
The M.C. Mehta v. Shriram Food and Fertilizer Industries case is a landmark in Indian environmental law and legal activism. It not only addressed critical constitutional questions, such as extending Article 21 to include the right to health but also introduced the Absolute Liability Principle to address the shortcomings of the traditional rule in Rylands v. Fletcher. Unlike the limited scope of strict liability, which provides exceptions for acts of God or third-party actions, absolute liability ensured hazardous industries were unconditionally accountable for damage caused. The case also catalysed the development of environmental legislation, which was enacted in the aftermath of the dual tragedies of Bhopal and Shriram. However, a contentious aspect of the case remains the Court’s interpretation of Shriram as a “state” under Article 12. While this interpretation expanded the scope of fundamental rights enforcement, critics argue that liability for violations of Article 21 should not hinge on whether an entity qualifies as a “state.” Instead, any private or public enterprise engaged in hazardous activities should be held accountable for fundamental rights violations. This case underscores the importance of ensuring corporate accountability and reflects the judiciary’s evolving stance on balancing industrial growth with environmental and constitutional rights.
CONCLUSION
The case underscores its significance as a judicial response to industrial disasters, reflecting the need for a proactive approach toward environmental governance. It illustrates the judiciary’s role not just in providing remedies for affected individuals but also in advancing broader systemic changes. By setting a precedent with the Absolute Liability Principle, the judgment ensured that hazardous industries prioritize public safety over profits. Furthermore, the case marked the rise of Public Interest Litigation as a tool for environmental justice and laid the foundation for creating specialized environmental courts in India. Importantly, it revealed gaps in administrative vigilance and the absence of a structured regulatory framework, emphasizing the need for legislative, executive, and judicial synergy to prevent future disasters. This case is a reminder of the shared responsibility between the state and private industries to uphold the constitutional values of human dignity, environmental protection, and sustainable development.
FAQS
What is the Absolute Liability Principle?
The principle holds industries dealing with hazardous substances unconditionally liable for any harm caused, with no exceptions. It replaced the outdated Rylands v. Fletcher rule and set a higher standard for industrial accountability in India.
Why was Shriram categorized as a “state” under Article 12?
The court considered Shriram a “state” because its operations involved activities of significant public interest. This categorization ensured accountability for fundamental rights violations, even though Shriram was a private entity.
What is the significance of the M.C. Mehta v. Union of India case?
The case is a milestone in environmental law, introducing the Absolute Liability Principle to ensure hazardous industries are fully accountable for harm caused. It also expanded the scope of Article 21 to include the right to a clean and safe environment, shaping future environmental governance.
What distinguishes this case from the Bhopal Gas Tragedy?
While both cases involved industrial disasters, the Shriram case introduced new legal doctrines like Absolute Liability and emphasized proactive judicial intervention, whereas the Bhopal case exposed administrative failures on a global scale.
