Published on: 11th November 2025
Authored by: Ishrat jahan
Asian Law College, Noida
Case Title: M.C. Mehta v. Union of India
Citation: AIR 1987 SC 965; 1987 SCR (1) 819
Court: Supreme Court of India
Bench: P.N. Bhagwati (CJI), R.S. Pathak, G.L. Oza, A.N. Sen, and Ranganath Misra, JJ.
Date of Judgment: December 20, 1986
Relevant Statutes/Key Provisions: Articles 21, 32, and 48-A of the Constitution of India
The Water (Prevention and Control of Pollution) Act, 1974
The Environment (Protection) Act, 1986
Brief Facts
The dispute developed as a result of environmental damage caused by the escape of oleum gas from Shriram Foods and Fertilizer Industries’ chemical factory in Delhi. The occurrence occurred shortly after the Bhopal Gas Tragedy, raising public health worries. M.C. Mehta, a public interest lawyer, filed a writ suit under Article 32, requesting strict environmental safeguards and the enforcement of the right to life under Article 21.
Issues Involved
- Can the right to life guaranteed by Article 21 be expanded to encompass the right to a healthy environment?
- What is the scope of liability for industrial units that cause environmental damage?
- Can the notion of strict responsibility be applied in hazardous industries?
Arguments
Petitioner’s Arguments
The right to life include the right to a healthy, pollution-free environment.
Industries involved in hazardous activity must have strong safety procedures.
Strict responsibility should be invoked to make the chemical facility liable for the damage done.
Respondent’s Arguments
The plant adhered to the relevant safety standards.
Absolute responsibility is too harsh for industries that contribute significantly to economic development.
Judgment
The Supreme Court ruled that the right to life under Article 21 includes the right to a pollution-free environment. The Court established the idea of absolute responsibility, which states that industries engaging in dangerous operations are entirely responsible for any harm produced, regardless of carelessness.
The Court ordered the formation of Environmental Courts to expedite the resolution of environmental complaints and underlined the necessity of sustainable industrial practices.
Ratio Decidendi
Industries involved in intrinsically risky or hazardous operations possess an absolute responsibility to guarantee that no harm is inflicted, regardless of measures or carelessness.
Obiter Dicta
The Court emphasized the judiciary’s responsibility in upholding environmental rights, as well as the importance of proactive environmental governance.
Final Decision
The Court found the Shriram Chemical Plant completely accountable for the gas leak and issued sanctions. It also provided orders for the execution of stronger environmental and safety regulations.
