M.C. Mehta Case (1986)
– Oleum Gas Leak and Constitutional Compensation
Background of the Case
In December 1985, a leakage of oleum gas occurred from the Shriram Food and Fertilizer Industries in Delhi.
The accident:
- Caused death and serious injury to several persons
- Raised grave concerns regarding industrial safety in densely populated areas
Environmental lawyer M.C. Mehta approached the Supreme Court under Article 32, seeking:
- Protection of the right to life (Article 21)
- Compensation for victims
Core Constitutional Questions
- Does Article 32 empower the Supreme Court to award compensation?
- Is the Court’s role only preventive or also remedial?
- What standard of liability applies to hazardous industries?
Supreme Court’s Judgement
The Supreme Court delivered a landmark ruling with far-reaching consequences.
(a) Article 32 Has Remedial as Well as Preventive Scope
The Court held that:
- Article 32 is not merely injunctive
- It is also remedial in nature
Therefore → The Supreme Court can grant relief for past violations of Fundamental Rights.
(b) Power to Award Compensation Under Article 32
The Court clarified that → In cases of gross and patent violation of Fundamental Rights → Where infringement is incontrovertible and ex facie glaring → The Court may → Award monetary compensation
Thus, compensation became a constitutional remedy, not merely a civil law claim.
(c) Article 21 as the Basis for Environmental Protection
The Court observed that:
- Applications seeking compensation were for:
- Enforcement of the Right to Life under Article 21
Hence → Such petitions are maintainable directly under Article 32
Introduction of the Principle of Absolute Liability
Perhaps the most revolutionary aspect of the judgment was the replacement of strict liability with absolute liability.
Key Features of Absolute Liability:
- Applies to hazardous or inherently dangerous industries
- No exceptions available
- Liability exists even without fault or negligence
- Defences under strict liability (like act of God) are not allowed
Thus → An enterprise engaged in hazardous activity is absolutely liable for harm caused.
Constitutional and Environmental Significance
This judgment:
- Expanded the scope of Article 21 to include environmental safety
- Strengthened Public Interest Litigation
- Converted the Supreme Court into a constitutional problem-solver
- Laid the foundation for:
- Polluter Pays Principle
- Environmental accountability
Impact of the Judgement
- Established constitutional tort jurisprudence
- Shifted environmental protection from:
- Policy domain → Rights domain
- Influenced later cases such as:
- Indian Council for Enviro-Legal Action (1996)
- Vellore Citizens’ Welfare Forum (1996)
Place in Constitutional Evolution
| Area | Contribution |
|---|---|
| Article 32 | Expanded to include compensation |
| Article 21 | Environmental safety included |
| Environmental law | Absolute liability doctrine |
Summary
The M.C. Mehta Case (1986) held that the Supreme Court under Article 32 can award compensation for gross violations of Article 21, and introduced the doctrine of absolute liability for hazardous industries.