MC Mehta v. Union of India – The Case that Changed Environmental Law in India

When we talk about environmental law in India, one name appears again and again, M.C. Mehta. He is a public interest lawyer who has filed several landmark petitions to protect the environment. Among his most famous cases is the Oleum Gas Leak case (1987), which completely transformed the way Indian law looks at industrial pollution and corporate liability. This case did not just solve one problem, it created a new legal principle that still protects millions of people today.

Background: A Leak That Shocked Delhi

The story begins in December 1985 at the Shriram Foods and Fertilizers Industry in Delhi. A poisonous gas called oleum gas leaked from the factory. This happened barely a year after the tragic Bhopal Gas Disaster of 1984, so the country was already sensitive to industrial safety failures.

The gas leak led to:

• Panic in surrounding areas

• Illness among residents

• The death of an advocate named Mr. Ram Nath Upadhyay

Concerned about public safety, M.C. Mehta filed a Public Interest Litigation (PIL) before the Supreme Court under Article 32 of the Constitution, arguing that people’s right to life under Article 21 was being violated.

Key Legal Question Before the Court

The Supreme Court had to answer a crucial question:

If a hazardous industry causes harm, what should be its legal responsibility?

Until then, courts followed the English principle of “strict liability” from the case Rylands v. Fletcher (1868). Under strict liability, an industry is responsible for damage caused by dangerous activity, but there were several exceptions, such as acts of God or third-party negligence.

But the Supreme Court felt that this rule was outdated for modern industrial India.

The Supreme Court’s Historic Decision

In 1987, a Constitution Bench headed by Justice P.N. Bhagwati delivered a groundbreaking judgment. The Court created a new doctrine called “Absolute Liability.”

What is Absolute Liability?

It means:

• If a company engages in hazardous or inherently dangerous activity

• And harm results from it

• Then the company is 100% responsible without exceptions

Unlike strict liability, no defenses are allowed.

So, even if:

• The accident was unexpected

• Safety measures were taken

• The cause was natural

…the company would still be liable.

The Court justified this by stating that industries earning profits from risky activities must bear the burden of costs when things go wrong.

The Court Also Said Something Very Powerful

The judges emphasized that:

• The right to a clean and safe environment is part of the Right to Life under Article 21

• Industries must ensure higher safety standards

• Compensation must match the size and financial strength of the enterprise

This meant bigger industries would have to pay higher compensation, ensuring accountability.

Why This Judgment Was Revolutionary

This case did three major things for Indian law:

1. Created the Doctrine of Absolute Liability

India became one of the first countries in the world to evolve this rule. It was stricter than English law, showing India’s independent legal vision.

2. Strengthened Environmental Protection

Environmental safety became a constitutional concern, not just an administrative matter.

3. Empowered Public Interest Litigation

The Court recognized that citizens could approach courts for environmental issues, even if they were not personally harmed.

Other Important MC Mehta Cases

M.C. Mehta didn’t stop after the Oleum Gas Leak case. Some of his other PILs led to major developments, such as:

• Ganga Pollution Case – Closure and regulation of polluting industries along the Ganga

• Taj Trapezium Case – Protection of the Taj Mahal from acid rain

• Vehicular Pollution Cases – Introduction of CNG fuel in Delhi

Together, these cases built the foundation of environmental governance in India.

Connection with Article 21 – Right to Life

The Court repeatedly said that life means more than mere survival. It includes:

• Fresh air

• Clean water

• A pollution-free environment

This interpretation has guided hundreds of later cases.

Criticism and Practical Challenges

Some critics argue that:

• Absolute liability may discourage investment in hazardous industries

• Implementation depends heavily on regulatory efficiency

However, supporters believe that human life and safety must always come first.

Impact on Later Laws

This case influenced major environmental laws and policies, including:

• Environment (Protection) Act, 1986

• National Green Tribunal Act, 2010

• Strict industrial safety rules and environmental clearances

Today, whenever a hazardous industry causes harm, courts rely on the principle laid down in this case.

Why This Case Still Matters Today

In an era of rapid industrialization, the risk of environmental disasters remains real. The Oleum Gas Leak case reminds industries that:

• Safety is non-negotiable

• Profit cannot come before people

• Law will hold them fully accountable

It also reminds citizens that the Constitution protects their right to live in a safe environment and courts are ready to step in.

Conclusion

The MC Mehta Oleum Gas Leak case (1987) is more than just a legal judgment, it is a milestone in India’s journey toward environmental justice. By introducing the doctrine of absolute liability and linking environmental safety with the right to life, the Supreme Court ensured that industries handling dangerous substances cannot escape responsibility.

This case proves that law is not static, it grows with society’s needs. And thanks to committed individuals like M.C. Mehta, India today has one of the strongest judicial frameworks for environmental protection.