In M.C. MEHTA v. UNION OF INDIA (Shriram Industries Case), AIR 1987 SC 965, the Supreme Court enunciated the doctrine of:

1. In M.C. Mehta v. UoI (Shriram Industries Oleum Gas Leak case), the Supreme Court (per Bhagwati CJI) articulated ABSOLUTE LIABILITY: 2. 'Where an enterprise is engaged in a hazardous or inherently dangerous activity and harm results to anyone on account of an accident in the operation of such hazardous or inherently dangerous activity resulting, for example, in escape of toxic gas, the enterprise is strictly and absolutely liable to compensate all those who are affected by the accident and such liability is not subject to any of the exceptions which operate vis-a-vis the tortious principle of strict liability under the rule in Rylands v. Fletcher.' 3. This is STRICTER than the Rylands v. Fletcher rule (1868) — no exceptions for act of God, act of stranger, etc. 4. Bhopal Gas Tragedy (1984) context influenced the doctrine. 5. Hence option B is correct. _Source: EPA 1986 / Constitution of India / Stockholm/Rio/Paris / Indian SC environmental jurisprudence — M.C. Mehta v. Union of India (Oleum Gas Leak / Shriram), AIR 1987 SC 965_