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India's Supreme Court redefines industrial liability with landmark ruling

A deadly factory leak in 1986 forced India's courts to abandon old rules. Now, industries bear total responsibility—no excuses allowed. The ruling still shapes justice today, but has it gone far enough?

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India's Supreme Court redefines industrial liability with landmark ruling

The legal landscape of liability in India took a major turn with the introduction of absolute liability. This principle, established by the Supreme Court, holds industries engaged in hazardous activities fully responsible for any harm caused—even without proof of negligence. The shift came as traditional fault-based systems struggled to keep pace with growing industrial risks.

The concept of strict liability first emerged in England through the 1868 case Rylands v. Fletcher. This ruling stated that if a dangerous substance escaped from a defendant's land and caused damage, they would be liable—provided the use of the land was non-natural and the substance had actually escaped. However, this doctrine had limitations, including exceptions for natural disasters or third-party interference.

In 1986, India's Supreme Court went further in M.C. Mehta v. Union of India. The case arose from a gas leak in a Delhi factory, which killed one person and injured several others. The court rejected the exceptions under strict liability and introduced absolute liability instead. Under this rule, enterprises dealing with hazardous activities are held fully accountable for any resulting harm, with no defences permitted.

The move reflected India's unique challenges as a developing nation. Rapid industrial revolution and technological growth had increased risks to public safety and the environment. Traditional fault-based liability often failed to protect victims or hold corporations accountable. Absolute liability, by contrast, aligned with constitutional values—particularly the right to life and a clean environment—ensuring stronger safeguards for those affected by industrial accidents.

While strict liability requires proof of specific conditions—such as the presence of a dangerous substance, its escape, and non-natural land useabsolute liability removes these hurdles. It places the burden entirely on industries engaged in inherently risky operations, reinforcing the principle that public welfare must take precedence over corporate interests.

The Supreme Court's ruling in M.C. Mehta v. Union of India set a precedent that remains foundational in Indian tort law. By eliminating exceptions and shifting the focus to victim protection, absolute liability provides a stricter framework for industrial accountability. However, no further legal developments or major case applications of this doctrine have been documented since the judgment.

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