M.C. Mehta v. Union of India (1987)
```
Quick Summary
After the Oleum gas leak from Shriram’s unit in Delhi, the Supreme Court faced a core question: how should law treat ultra-hazardous industries near crowded areas? The Court introduced the Absolute Liability rule—if such an industry causes harm, it is fully liable, no excuses.
Issues
- Should such hazardous units be allowed to operate in dense localities?
- If allowed, what regulatory mechanism must govern them?
- Is the Absolute Liability rule the correct standard?
Rules
Absolute Liability
An industry engaged in hazardous activity is absolutely liable for harm from an accident—no defences, no exceptions.
Public Safety Priority
Operations must respect Article 21. Safety systems and location controls are essential.
Facts (Timeline)
Factory & Location: Shriram’s caustic chlorine & sulphuric acid units in densely populated Kirti Nagar, Delhi (~2 lakh residents).
PIL Filed: M.C. Mehta moved the Supreme Court under Articles 21 & 32 seeking closure/relocation.
Oleum Leak: A major leak injured many; a minor leak followed two days later; compensation claims were filed by Legal Aid bodies.
Magistrate’s Action: Orders under Section 133(1) to stop producing/keeping dangerous chemicals within 7 days.
Key Legal Question: How to fix liability and regulate ultra-hazardous industries in urban areas?
SC Review: Case referred to the Supreme Court due to constitutional importance.
Arguments
Appellant (M.C. Mehta)
- Hazardous units in crowded zones threaten life and health (Art. 21).
- Liability must be strictest possible to deter negligence.
- Closure/relocation and strong oversight are necessary.
Respondents (Shriram/State)
- Essential industry; jobs and supply chains will suffer.
- Compliance measures taken; further improvements planned.
- Older strict liability may suffice without a new standard.
Judgment
The Supreme Court adopted the Absolute Liability rule for ultra-hazardous industries. Old strict liability was inadequate for modern risks. The Court also pressed for green belts (1–5 km) around such sectors and called for a specialized Environmental Court with expert members.
Ratio (Reason for Decision)
Where activities are inherently dangerous, the duty to safeguard the public is absolute. If harm occurs, liability is total and cannot be avoided by excuses or due-care claims.
Why It Matters
- Builds a people-first safety standard for modern industry.
- Shapes urban planning: buffer zones and relocation near dense areas.
- Boosts enforcement through expert environment courts.
Key Takeaways
Ultra-hazardous units are liable for harm without defences.
Maintain a 1–5 km protective green belt around such industries.
Set up an Environmental Court with scientific experts.
Right to life includes protection from industrial hazards.
Mnemonic + 3-Step Hook
Mnemonic: “A-G-E = Absolute — Green belt — Environment Court”
- Absolute: Liability is total for hazardous harm.
- Green belt: Keep a wide protective buffer.
- Env. Court: Judges + experts for quick, sound relief.
IRAC Outline
Issue
Can hazardous industries operate in dense areas, and what standard governs their liability?
Rule
Absolute Liability for ultra-hazardous activity; public safety under Article 21.
Application
Oleum leak showed grave risk to nearby population; older strict liability was insufficient.
Conclusion
Adopted Absolute Liability; ordered systemic safeguards like green belts and expert court.
Glossary
- Absolute Liability
- Full liability for harm from hazardous activity without exceptions.
- Strict Liability
- Older rule with defences; replaced here by absolute liability for such industries.
- Section 133 CrPC
- Provision allowing a Magistrate to remove public nuisances urgently.
- Green Belt
- Protective vegetated buffer around industrial zones.
FAQs
Popular & Recent Post
Comment
Nothing for now