Absolute liabilityStrict liabilitySupreme Court of India

MC Mehta v Union of India (Oleum Gas Leak)

AIR 1987 Supreme Court 108619871 min read

The case in brief30-second read

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: 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.
Principle: Enterprises engaged in inherently dangerous activities owe ABSOLUTE liability, no defences available; damages proportional to magnitude of enterprise

Cite this

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

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.

Exam use

How to use it in an answer

| Subject | How Applied | Chapter |
|---------|------------|---------|
| Jurisprudence | Illustrates absolute liability as Indian development beyond English strict liability | JUR 4.4 Negligence Strict Liability and Accident |

Cite this

Citation

MC Mehta v Union of India (Oleum Gas Leak) AIR 1987 Supreme Court 1086

Reported: AIR 1987 Supreme Court 1086. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.