What was the main issue in this case?

Whether running a defective MIC plant without care and without public warning amounted to gross criminal negligence.

How is criminal negligence different from civil negligence?

The idea of negligence is the same, but criminal negligence must be gross—far below the standard of reasonable care.

What happened on the night of 2–3 December 1984?

MIC leaked from Tank 610 at UCIL, Bhopal, causing thousands of deaths and injuries to lakhs of people and animals.

Company officers responsible for safety and operations were held liable for breach of duty; the corporation was found guilty under IPC sections 304A, 336, 337, and 338 read with 35.

What legal principle did the Court apply?

A company owes a duty of care. If conduct falls far below that duty, it is gross negligence leading to criminal liability.

State of Madhya Pradesh v. Warren Andreson

Criminal Case No. 8460/1996 • Supreme Court of India • Industrial Disaster & Criminal Negligence

Supreme Court 1984 (incident) Bhopal Gas Tragedy IPC 304A, 336–338 r/w 35 Criminal / Tort Principles ~7 min read

PRIMARY_KEYWORDS: Bhopal gas tragedy; gross criminal negligence; duty of care SECONDARY_KEYWORDS: MIC leak; Union Carbide; IPC 304A 336 337 338; public warning

AUTHOR_NAME: Gulzar Hashmi LOCATION: India PUBLISH_DATE: 31 Oct 2025 Slug: state-of-madhya-pradesh-v-warren-andreson

Quick Summary

The Court treated the Bhopal MIC leak as a result of gross criminal negligence. Running a defective, high-risk plant without proper care, and failing to warn nearby residents, breached the duty of care. Officers responsible for operations and safety were held liable. The corporation was found guilty under IPC 304A, 336, 337, 338 read with 35.

```

Issues

Can accused be held guilty for negligible/grossly negligent operation of a defective MIC plant without reasonable care?
Does failure to inform local people about preventive steps show gross negligence in criminal law?

Rules

Duty of care: A company owes a continuing duty of care in hazardous operations. If conduct falls far below the standard of a prudent operator, it is gross negligence.

Civil vs Criminal negligence: Conceptually similar; criminal negligence requires a higher threshold—conduct so bad it shows disregard for life and safety.

Facts (Timeline)

Timeline visual for Bhopal gas tragedy case

Corporate structure: UCIL (India) was controlled by UCC (USA) through UCE Inc. Regional Office.

License conditions: MIC-based pesticide manufacturing had to be free from air, water, and soil pollution; processes were extremely hazardous.

Plant operations: MIC produced and stored in underground tanks—Nos. 610, 611, and 619—at UCIL, Bhopal.

Leak event: Between 12:00–12:45 AM, 2–3 Dec 1984, MIC escaped from Tank 610, killing thousands and injuring lakhs. No timely warning or on-site information was provided to residents.

Prosecution: CBI filed a charge sheet against Warren Andreson (UCC Chairman) and others. The case went through Sessions Court and was considered by the Apex Court.

Arguments

Prosecution

Plant was defective; safety systems and protocols were inadequate.
Operators and officers ignored known risks and warnings.
Failure to alert the public showed reckless disregard for life.

Defence

Compliance with licenses and internal standards was claimed.
Leak was an unforeseen accident; no intention to harm.
Criminal liability should not follow from mere operational failure.

Judgment

The Court found a chain of circumstances—supported by expert and employee evidence—showing negligent conduct across roles; the tragedy was preventable.
Omissions by those entrusted with safety amounted to gross criminal negligence.
Responsible officers who allowed MIC to escape from Tank 610 were liable for breach of duty of care.
Holding: The corporation was guilty under IPC 304A, 336, 337, 338 read with 35 and liable to be punished.

Ratio (Legal Principle)

In hazardous industries, continued operation without robust safeguards and public warning is not mere carelessness; it is gross negligence, attracting criminal liability.

Why It Matters

Sets a strong standard of criminal accountability for industrial disasters.
Highlights duty to warn and to maintain working safety systems.
Bridges tort principles with criminal law via the “gross” threshold.

Key Takeaways

High-risk = high duty: Hazardous plants must meet strict, continuous safety standards.
Warn the public: Failure to alert communities can evidence gross negligence.
IPC liability: 304A & 336–338 r/w 35 apply when omissions cause mass harm.

Mnemonic + 3-Step Hook

Mnemonic: “MIC = MUST INFORM & CARE”

MUST have working safeguards.
INFORM public in danger.
CARE = continuous duty; failure = gross negligence.

IRAC Outline

Issue: Whether running a defective MIC plant without public warning and reasonable care amounts to gross criminal negligence.

Rule: Duty of care applies; criminal negligence requires conduct far below reasonable standards.

Application: Evidence showed preventable failures and omissions by responsible officers; no adequate warning to residents.

Conclusion: Liability under IPC 304A, 336–338 r/w 35 established; corporation guilty.

Glossary

MIC (Methyl Isocyanate): A highly toxic chemical used in pesticide production; requires strict containment and monitoring.
Gross Negligence: Conduct far below reasonable care, showing disregard for life/safety—basis for criminal liability.
IPC 304A: Causing death by negligence (no intent, but culpable carelessness).