Absolute liabilityOleum gasSupreme 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 Food and Fertilizer complex in Delhi (December 1985) One person died, several others injured. MC Mehta filed PIL under Articles 21 and 32.
Issue
Whether the rule in Rylands v Fletcher (strict liability with exceptions) applies, or a higher standard is required for hazardous industrial activity in India.
Held
Rylands v Fletcher is a 19th-century rule developed for an agrarian economy.
Principle
An enterprise engaged in inherently dangerous activity is absolutely liable for harm caused, with no exceptions (no act of God, no third-party defence, no consent). Compensation must be proportionate to the magnitude and financial capacity of the enterprise.
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Facts

  • Oleum gas leaked from Shriram Food and Fertilizer complex in Delhi (December 1985)
  • One person died, several others injured
  • MC Mehta filed PIL under Articles 21 and 32
  • Question: what liability standard applies to hazardous industries?

Issue

  1. Whether the rule in Rylands v Fletcher (strict liability with exceptions) applies, or a higher standard is required for hazardous industrial activity in India.

Held

  • Rylands v Fletcher is a 19th-century rule developed for an agrarian economy
  • India needs a rule suited to its industrial context
  • Absolute liability established: no exceptions apply (no act of God, no third-party defence, no consent)
  • Compensation must be proportionate to the magnitude and financial capacity of the enterprise
  • The larger the enterprise, the greater the compensation (deterrent principle)

Ratio decidendi

Where an enterprise is engaged in an inherently dangerous or hazardous activity and harm results, the enterprise is absolutely liable to compensate, regardless of whether it exercised due diligence. The measure of compensation must correspond to the magnitude of the enterprise. No defences available under Rylands v Fletcher apply.

Exam use

How to use it in an answer

  • Part A: Landmark on absolute liability (Indian development beyond Rylands v Fletcher). Art.21 expansion into environmental/industrial liability.
  • Part B: Key distinction: Strict liability (Rylands, defences available) vs Absolute liability (MC Mehta, NO defences, enterprise-proportionate compensation).
  • Key line: "The Supreme Court evolved the doctrine of absolute liability for hazardous industries: no exceptions apply and compensation must be proportionate to the enterprise's capacity."

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Citation

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

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