M.C. Mehta v Union of India (1987)

Law of Torts · Absolute Liability

Facts.

Oleum gas escaped from a plant of Shriram Foods and Fertilisers in a densely populated part of Delhi, one year after the Bhopal disaster, injuring several people and killing one. The question of the plant’s liability came before the Supreme Court in a public interest petition.

Issue.

Should the English rule in Rylands v Fletcher, with its exceptions, govern the liability of a hazardous enterprise in India?

Held.

No. Bhagwati CJ held that an enterprise engaged in a hazardous or inherently dangerous activity owes an absolute and non-delegable duty to the community, subject to no exceptions, and that compensation should be correlated to the magnitude and capacity of the enterprise so as to have a deterrent effect.

Why it matters.

It is the clearest instance of Indian tort law departing from and improving on English precedent, and it is the second half of every “how far has Rylands been modified?” question.

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