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As per case facts, petitioners sought closure of Shriram Foods & Fertilizers units due to hazardous operations. During the petition's pendency, an oleum gas leak occurred, prompting applications for compensation
...for affected persons. The question arose regarding the Supreme Court's jurisdiction under Article 32 to award compensation for fundamental rights infringement, whether Article 21 could apply against a private corporation like Shriram engaged in public interest industry, and the measure of liability for enterprises in hazardous industries, questioning the applicability of the Rylands v. Fletcher rule in India. Finally, the Supreme Court ruled that Article 32 encompasses remedial powers, allowing compensation for gross and patent fundamental rights violations, especially for disadvantaged persons. While deferring the Article 21 question for Shriram, the Court established a new principle of "absolute liability" for hazardous industries, making them strictly liable for harm regardless of negligence. Compensation must be proportionate to the enterprise's size and capacity, serving as a deterrent, and victims' cases were directed to be handled by the Delhi Legal Aid and Advice Board.
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