UPSC MainsLAW-PAPER-II202215 Marks
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Q8.

How is the rule of 'absolute liability' different from 'strict liability'? Cite the relevant judgements.

How to Approach

This question requires a comparative analysis of two tort law principles: strict liability and absolute liability. The answer should begin by defining both concepts, highlighting their origins and key characteristics. A clear distinction should be made, focusing on the defenses available under each principle. Crucially, relevant landmark judgements establishing these principles – Rylands v Fletcher (strict liability) and M.C. Mehta v Union of India (absolute liability) – must be cited and explained. The answer should be structured to first explain strict liability, then absolute liability, and finally, a direct comparison.

Model Answer

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Introduction

In tort law, both strict liability and absolute liability are exceptions to the general principle that fault must be proven to establish negligence. These doctrines aim to provide redress to victims of hazardous activities, even in the absence of intent or carelessness. While both impose liability without fault, they differ significantly in their scope and the availability of defenses. The evolution from strict liability, as established in the classic case of *Rylands v Fletcher* (1868), to absolute liability, as articulated in *M.C. Mehta v Union of India* (1987), reflects a growing concern for public safety and environmental protection in the context of rapidly industrializing nations like India.

Strict Liability

Strict liability, originating from the landmark English case *Rylands v Fletcher* (1868 LR 3 HL 330), holds a person liable for damages caused by a dangerous thing brought onto their land that escapes and causes harm. The principle states that if someone brings onto their land something likely to do mischief if it breaks out, they are liable for all the damage which is the natural consequence of its escape, regardless of whether they took reasonable care.

  • Essential Conditions:
    • Dangerous thing
    • Brought by the defendant onto their land
    • Escape of the dangerous thing
    • Non-natural use of land
    • Resulting damage
  • Defenses Available: Several defenses can be pleaded under strict liability:
    • Act of God: An extraordinary natural event that could not be foreseen.
    • Default of the Plaintiff: Damage caused by the plaintiff’s own negligence.
    • Force Majeure: An irresistible force or unforeseen event.
    • Statutory Authority: If the activity is authorized by a statute.

Absolute Liability

Absolute liability, a stricter standard, was developed in India in the case of *M.C. Mehta v Union of India* (1987 AIR 969, SCR (2) 798). This principle arose from the Bhopal Gas Tragedy (1984), which exposed the limitations of strict liability in dealing with hazardous industries. The Supreme Court held that when an enterprise is engaged in a hazardous or inherently dangerous activity, it has an absolute and non-delegable duty to ensure that the activity is conducted with utmost care and safety, and it must be absolutely liable for any harm resulting from the activity, regardless of whether reasonable care was taken.

  • Essential Conditions:
    • Hazardous or inherently dangerous activity
    • Harm resulting from the activity
  • No Defenses Available: Crucially, unlike strict liability, no defenses are available under absolute liability. The enterprise is liable even if it took all reasonable care and there was no negligence. The only exception is if the harm was caused by a third party, over whom the enterprise had no control.

Comparison: Strict Liability vs. Absolute Liability

The following table summarizes the key differences between the two principles:

Feature Strict Liability Absolute Liability
Origin Rylands v Fletcher (1868) M.C. Mehta v Union of India (1987)
Standard of Care Reasonable care is relevant; liability arises from the escape of a dangerous thing. Highest degree of care required; liability arises from the inherently dangerous nature of the activity.
Defenses Act of God, Plaintiff’s Default, Force Majeure, Statutory Authority No defenses (except harm caused by a third party beyond control)
Scope Applies to non-natural use of land. Applies to hazardous and inherently dangerous industries.
Focus Escape of a dangerous substance. The inherent risk associated with the activity itself.

The Bhopal Gas Tragedy highlighted that the defenses available under strict liability could be exploited by industries to evade responsibility. Absolute liability was thus introduced to ensure that industries engaged in hazardous activities bear the full cost of potential harm, incentivizing them to prioritize safety and prevent disasters.

Conclusion

In conclusion, while both strict and absolute liability aim to provide compensation to victims of hazardous activities without proving fault, absolute liability represents a significant departure from the traditional common law principle. The Indian judiciary, recognizing the unique challenges posed by rapidly industrializing economies and the potential for large-scale disasters, adopted absolute liability to ensure greater accountability and public safety. This shift underscores the evolving nature of tort law in response to societal needs and environmental concerns.

Answer Length

This is a comprehensive model answer for learning purposes and may exceed the word limit. In the exam, always adhere to the prescribed word count.

Additional Resources

Key Definitions

Tort
A civil wrong, other than a breach of contract, for which a remedy may be obtained, usually in the form of damages.
Non-Delegable Duty
A duty that cannot be transferred to another party. Under absolute liability, the enterprise has a non-delegable duty to ensure safety.

Key Statistics

According to the National Crime Records Bureau (NCRB), India reported 4,72,787 cases of accidental deaths and suicides in 2022, many of which could potentially involve industrial accidents and related tort claims.

Source: NCRB, Accidental Deaths & Suicides in India 2022

India's chemical industry is estimated to contribute around 7% to the country's GDP (as of 2023). This highlights the economic importance of the sector, but also the potential risks associated with hazardous chemical processes.

Source: Department of Chemicals and Petrochemicals, Government of India (Knowledge cutoff 2023)

Examples

Oleum Gas Leak Case

The *M.C. Mehta v Union of India* case (1987) itself arose from a leak of oleum gas from a Shriram Foods and Fertilizers Ltd. plant in Delhi, causing severe respiratory problems to residents. This case led to the formulation of the principle of absolute liability.

Frequently Asked Questions

Is absolute liability applicable to all industries?

No, absolute liability is specifically applicable to industries engaged in hazardous or inherently dangerous activities, posing a significant risk to public health and safety. It doesn't apply to all industries generally.

Topics Covered

LawTort LawEnvironmental LawLegal Principles