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Charan Lal Sahu vs. Union of India (1990): Grappling with Corporate Liability and Public Interest

The case of Charan Lal Sahu vs. Union of India (1990) is a landmark judgment that arose in the aftermath of the Bhopal Gas Tragedy, one of the most horrific industrial disasters the world has ever seen. The case delved deep into issues of corporate liability, compensation, and the role of the state in safeguarding public interest, especially in the face of colossal human tragedies.

1. Background of the Case

On the night of December 2-3, 1984, a leak of methyl isocyanate gas from the Union Carbide plant in Bhopal led to the death of thousands, while affecting the health and well-being of several thousands more. In the wake of the disaster, several petitions were filed for compensation and for stricter regulations on corporations to prevent such tragedies in the future.

2. The Core Issue

Charan Lal Sahu, an advocate, filed a writ petition questioning the constitutional validity of the Bhopal Gas Leak Disaster (Processing of Claims) Act of 1985. The Act provided the central government exclusive rights to represent all victims of the disaster, thereby barring individual litigations for compensation against Union Carbide Corporation.

3. The Court’s Decision

The Supreme Court, in a majority decision, upheld the constitutional validity of the Act. The court’s rationale was:

  • Public Interest: Given the magnitude of the tragedy, the court recognized the need for a consolidated approach to compensation. Individual litigations might lead to inconsistencies and delays in dispensing justice.
  • Administrative Pragmatism: The sheer number of affected individuals would make individual litigations an administrative nightmare.
  • Efficacy of the Central Government: The court placed trust in the central government to represent the best interests of all the victims.

4. The Significance of the Judgment

  • Redefining Corporate Liability: The case spotlighted the concept of corporate responsibility and the extent to which corporations can be held accountable for negligence.
  • State as the Guardian: By upholding the Act, the Supreme Court entrusted the central government with the role of being the sole representative of public interest in such vast tragedies.
  • Critiques and Concerns: While the judgment streamlined the compensation process, it also faced criticism for potentially limiting the rights of victims to seek individual redressal.

5. Broader Implications

  • A Blueprint for Future Disasters: The judgment and the Act provided a potential roadmap for dealing with large-scale industrial disasters in terms of compensation and redressal.
  • The Corporate-Government Nexus: Post the judgment, discussions intensified around the relationship between corporations and governments, especially concerning accountability and the protection of public interest.
  • Human Rights Concerns: The scale of the tragedy and the subsequent legal battles brought to the forefront the debate on human rights, corporate ethics, and the role of the state in safeguarding its citizens.


Charan Lal Sahu vs. Union of India (1990) remains an essential reference point in discussions related to corporate accountability, state responsibility, and the rights of citizens in the face of large-scale industrial disasters. The case, emerging from one of the darkest chapters in industrial history, highlights the complex interplay between corporate interests, state responsibility, and the inalienable rights of citizens. The judgment, while not without its critics, underscores the challenges faced by the judiciary in balancing diverse interests in the pursuit of justice.

Shivendra Pratap Singh


High Court Lucknow

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