MC Mehta v Union of India (Oleum Gas Leak)

Facts

• Oleum gas leaked from Shriram Industries' plant in Delhi, causing harm to workers and residents of nearby slums. This occurred shortly after the Bhopal gas tragedy (1984). MC Mehta (public interest litigant) filed under Art.32 seeking compensation and enhanced liability standards for hazardous industries.

Issue

1. Whether the rule in Rylands v Fletcher (1868), with its defences, is adequate for hazardous industries in India, or whether a stricter standard should apply.

Held

• The Supreme Court (5-judge bench, per Bhagwati CJ) held that Rylands v Fletcher is inadequate for India. The Court created a NEW rule of ABSOLUTE LIABILITY: an enterprise engaged in inherently dangerous activity owes an absolute duty to the community. NO exceptions or defences are available (not even Act of God, consent, or act of stranger). Damages must be proportional to the MAGNITUDE of the enterprise.

Ratio Decidendi

The Supreme Court (5-judge bench, per Bhagwati CJ) held that Rylands v Fletcher is inadequate for India. The Court created a NEW rule of ABSOLUTE LIABILITY: an enterprise engaged in inherently dangerous activity owes an absolute duty to the community. NO exceptions or defences are available (not even Act of God, consent, or act of stranger). Damages must be proportional to the MAGNITUDE of the enterprise.