A landmark judgment under the Factories Act, 1947 is the case of "M.C. Mehta v. Union of India" (1987), which set significant precedents in interpreting workplace safety and environmental standards under the Act.
Key Points of the Case:
Background: The case arose from the Oleum Gas Leak incident in Delhi in 1985, where toxic gas leakage from a factory resulted in the death of several people and injuries to many. This incident raised serious concerns about industrial safety, environmental protection, and liability under the Factories Act and other relevant laws.
Doctrine of Absolute Liability: The Supreme Court introduced the principle of absolute liability, which holds industries engaged in hazardous activities strictly liable for any harm caused, regardless of negligence. This was a departure from the traditional principle of strict liability that provided exceptions under certain circumstances. The court stated that industries handling hazardous substances owe a high duty of care to the public and environment.
Factories Act, 1947: The judgment emphasized the need for stricter implementation of safety provisions under the Factories Act, 1947. This includes ensuring proper maintenance of machinery, safe handling of hazardous substances, and adequate emergency plans to protect workers and nearby residents.
Public Interest and Environmental Safety: The judgment strengthened the application of the Factories Act in protecting both workers and the public from industrial hazards. It also called for reforms in monitoring and regulatory oversight by government agencies.
Establishment of Green Bench: Following this case, the Supreme Court directed the establishment of special courts, often called "Green Benches," to address cases concerning environmental and industrial safety issues.
Impact of the Judgment:
- The case highlighted the importance of workplace safety in industries, especially those dealing with hazardous materials, under the Factories Act.
- It enhanced employer accountability for ensuring the safety and health of workers.
- This judgment also inspired future laws on environmental protection and industrial safety in India, such as the Public Liability Insurance Act, 1991.
The M.C. Mehta case is widely regarded as a milestone in labor law and industrial safety regulations, setting a high standard for employer responsibility under the Factories Act, 1947.
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