IS GAS TRAGEDY AN UPCOMING DISASTER?

Author: Akshara KV, 4th Year, SDM Law College, Mangalore. The author has written the research article while pursuing the internship programme with us.

ABSTRACT

Nowadays in India, gas tragedy is one of the major disasters. The Bhopal gas tragedy is the worst industrial disaster in the history of mankind. After the Bhopal gas tragedy in 1984, the Visakhapatnam gas tragedy was deemed to be the second worst industrial accident occurred in 2020. In many parts of India gas tragedy had occurred. These killed thousands of people immediately. Many are suffering health issues due to this accident. Methyl isocyanate “MIC” was the gas leaked in Bhopal. It was due to the over pressurization of the gas. It causes human health by various diseases like respiratory problems, blindness etc. not only to human beings it also causes damage to all the living organisms. Source of the gas leak occurred in Visakhapatnam was a styrene plant and the cause leads to gas leak is stagnation and changes in temperature inside the storage tank that could have resulted in auto polymerization and vaporization of the styrene. There are some legal consequences relating to the gas tragedy like criminal liability, tortious liability, absolute liability and all. Also various scholars have made a study on these gas tragedies based on the medical conditions of different peoples who are the victims of this disaster. Finally, the Government passed a series of compensation for the victims and made preventive measures for the environmental disasters.          

KEYWORDS – Gases, industries, chemicals, diseases, health.

INTRODUCTION 

There are several industries in India. The major industries in the Indian economy are iron, steel, petrochemical, automobiles etc. iron and steel industry is one of the most important industries considering total investments. Therefore, all these industries produce lots of chemicals and gases. All these gases are very dangerous to the human body and also to the environment. In India, gas leakage has happened tremendously. It killed thousands of people and many peoples have caused various health issues relating to this tragedy. People have suffered respiratory issues and so many diseases resulting from this exposure. The main issue faced by the people is, nobody knew how to treat the toxin. And another main factor is that, the children born to mothers who were exposed to the gas were also the victims of the tragedy. Even after 20 or 30 years (after the exposure) there are no changes in the health condition. There was negligence and lack of maintenance. Because of the exploitation of gas, all the chemicals and waste materials of factories flowed into the water and the water was contaminated. People drink this water and cause so many diseases. The affected subjects are known to suffer from chronic illnesses such as pulmonary fibrosis, bronchial asthma, chronic obstructive pulmonary disease (COPD), emphysema, recurrent chest infections, keratopathy and corneal opacities. Studies have shown that these survivors had faced a severe occurence in a higher extent of reported health problems including febrile illnesses, respiratory, neurological, psychiatric and ophthalmic symptoms.[1] India has been experiencing rapid industrialization with GDP per capita going up to US$ 2900 in 2004 and the economy grew at over 7–8% every year. Rapid industrial growth has contributed immensely to the economic growth but there has been significant cost in the form of environmental degradation and increased public health risks. Increasing awareness of potential exposures to exogenous non-biological agents arising out of human activity will become an important issue for this century. These exposures and their aftermath give rise to many questions like safety of health, progeny safety, based on the matter of compensation and punishments  and so on. In spite of facts, MIC related accidents or an accident of similar magnitude may or may not happen again, but for a country like ours which is distressed with human, environmental and economic insecurity, analyzing the long standing effects of the disaster will be of massive value and important while coming across the future chemical disasters. Although there has been an international agreement on the fact that the nature, seriousness of damage and conscious endurance of pain in the survivors of the accident are of brilliant order, attempts at understanding the pertinacity of long standing effects are procrastinating from both academia and industry. The study of the human aspect of the tragedy was perhaps delayed behind and there has been a lack of prudent planning to assimilate studies on the long-term health consequences of the tragedy. investigators conducted studies on this and they have also raised a new question :-  how long the gas victims will continue these multi  disorders and whether their upcoming generations will affect these abnormalities. In-depth molecular studies of ocular, respiratory, reproductive, immunological, genetic and psychological health must be continued if we wish to understand the extent and severity of long term effects associated with the disaster.[2] 

SCOPE OF THE STUDY

 Gas tragedies have occurred in several parts of our country. The main scope of this study is to understand the basic knowledge on the legal consequences of gas tragedy, the Government has propounded so many acts to compensate the victims and also there are some measures to prevent these accidents. And we will know how these gas leakage affects the peoples and all other living organisms after 20-25 years and more.  

RESEARCH QUESTIONS                                           

1. To analyze the long term effects of harmful chemicals on the human body and environment.

2. To address the legal consequences and measures to be taken before and after a gas leakage.

HYPOTHESIS

Increased exposure to harmful chemicals from industrial accidents cause long-term impact to the environment and health of living organisms.

METHODOLOGY

This paper highlights the major industrial disasters taking place in India focusing on gas tragedies occurred since 1984. Safeguards for a healthy functioning industry and the legislations that are adopted with the aim to achieve a wholesome environment has been included in this paper and also comprises my personal suggestions which have  been incorporated as the conclusion of the essay. The data collected in the said paper has been collected and theoretically in great detail.

LITERATURE REVIEW

Sajal De, 2012 performed a retrospective study among surviving methyl isocyanate (MIC) gas victims of Bhopal Gas Tragedy and compared it with the non-MIC exposed (non gas exposed) population. Study showed that the relative risk for pulmonary function abnormalities in gas victims was significantly more among those who were young at the time of disaster. Male gas victims were more affected by severe airflow obstruction than females.[3]

P. Cullinan, S. Acquilla and V. Ramana Dhara, examined the role of exposure to the 1984 Bhopal gas leak in the development of persistent obstructive airways disease. The study showed that the respiratory symptoms were most common and lung functions were reduced. In this study respiratory disease attributable to gas exposures was detected in adult survivors.[4]

B.B. Ghosh, S. Sengupta, A. Roy, S. Maity, S. Ghosh, G, Talukder and A. Sharma, performed cytogenetic studies in human populations exposed to gas leak at Bhopal. The study showed that, et al analyzed 129 peoples from Bengal, India. Of these, 83 persons had been exposed directly to the methyl isocyanate gas after the accident. Remaining 46 samples were taken from age-matched persons from Bhopal itself. The frequency of chromosomal aberrations was higher in individuals from the exposed populations, with the females showing a higher incidence.[5] 

N.S. Anjana, M.V. Harindranathan Nair, K.S. Sajith, A. Amarnath, I. Indu studied to assess the impacted area of ammonia toxicity from a storage facility under different atmospheric conditions of a day. The air dispersion model was used in this study. And the result shows that there is a significant difference in the impacted area of an ammonia leak under different conditions.[6] 

GAS TRAGEDIES OCCURRED IN INDIA

Bhopal

The Bhopal gas tragedy is undoubtedly one of the worst industrial disasters in the history of mankind. On December 3, 1984, the dangerous gas methyl isocyanate leaked from a pesticide plant that was owned by the Indian subsidiary of the American firm Union Carbide Corporation (UCC). This killed thousands of people immediately. The final death toll was evaluated around 15,000 and 20,000. Some people survived from the death but they are suffering from respiratory problems, blindness etc. This factory was made to produce a pesticide. Trade unions of Bhopal complained over this plant. A worker accidentally inhaled the toxic gas which leads to his death within hours.[7]

Leakage of methyl isocyanate gas has happened due to the over pressurization of liquid MIC. Because the tank was allowed to be filled only upto 50% of its capacity and the tank was pressurized with inert nitrogen gas. Still one of the tanks lost the ability to contain nitrogen gas pressure, hence liquid MIC could not be pumped out of it. This tank had 42 tonnes of MIC. This caused to the leakage.

Leakage of methyl isocyanate gas led to the death of thousands of people and affected over 6, 00,000 peoples. The impact of gas leakage held not only to the humans. It also affected the animals, birds, trees and all. Trees became unproductive. Animals have swelled. People ran on the streets by vomiting and finally died. The Bhopal city had become a cremation ground.

Sudden health effects include ulcers, respiratory issues, abdominal pain, impaired audio, impaired reasoning ability etc.

Long term health effects include decreased lung functions, pregnancy loss, infant mortality etc.[8]  

Tughlakabad, Delhi

On May 6, 2017, gas leak was reported from a container depot next to Rani Jhansi Sarvodaya Kanya Vidyalaya and Senior Kanya Vidyalaya in Tughlakabad area. The gas leakage had affected more than 450 children from two schools in Tughlakabad, who had grouched for the issues caused to them like skin irritation, sore eyes and dizziness and  immediate treatment was taken. The liquid chemical, which has been identified as chloromethyl pyridine, a chemical used in manufacturing insecticides and pesticides, is believed to have leaked from a couple of broken barrels inside an iron container, which was kept in the depot overnight before being transported to Sonepat in Haryana early on Saturday. This chemical is used in fertilizers, pesticides and certain drugs and it is highly irritable to the eyes and lungs. Investigations are going on to find out what caused a tear in the plastic containers that stored the chemicals. Failure of the material or packaging containers keeping in mind Indian weather conditions.[9]

Belur, Karnataka

 Almost 25 people were hospitalized after inhaling chlorine gas that leaked from a water treatment plant on the outskirts of Belur on May 16, 2017. Breathlessness, nausea and burning sensation in the throat were the symptoms of people who inhaled the gas.[10]

Mangalore, Karnataka

 On November 17, 2016, a gas leak in an HPCL running between Mangalore-Hassan-Mysore and Sollur created panic in villages in the area. Several people were reportedly hospitalized after they inhaled the gas. The leak was identified early.[11]

Kanpur, Uttar Pradesh

 Almost five people were killed and many were injured seriously in an explosion caused by an ammonia gas leak in the Katiyar cold storage in Kanpur on March 15, 2017. The explosion caused the roof of the building to collapse, trapping several people.[12] 

Nagaram, Andhra Pradesh 

 On June 27, 2014, an enormous fire broke out leading to a blast in the Gas Authority of India Limited’s plant, killing 29 people and injuring 10. The 18-inch underground pipeline was used to transport the wet gas having condensate/water. This destroys the pipe and leads to a gas leak. A flame induced the explosion and the subsequent fire.[13]

Bhilai

On the 9th of October 2018, fourteen workers were burnt alive and another ten were seriously injured in a gruesome accident in the Energy Management Department of Bhilai Steel Plant (BSP).

It said there was a fire in a gas pipe line of Coke Oven Battery Complex No. 11 during a scheduled maintenance job.

The Chhattisgarh government’s industrial health and safety department, after an initial inquiry, has declared that, during the time of accident there was no proper maintenance. But officials working in the plant say that the biggest failure was the negligence of the senior management. they didn’t  set up a lawful safety committee in the last two years. Committee has the responsibility to ensure the strict execution of occupational safety norms.

In the same year, three accidents had earlier taken place at the plant — on 8, 9 and 10 May. SAIL had suffered 20 deaths due to this accident in its plant in 2015, 11 occurred in 2016 and 16 took place in 2017.[14]

Visakhapatnam 

A severe chemical accident occurred at Visakhapatnam in Andhra Pradesh in India on 7 may 2020. A technical glitch in the refrigeration unit connected to 2 styrene tanks caused a massive toxic vapor leak. Styrene gas had disseminated over the radius of almost 3 kilometres and killed atleast11 people and hospitalized over 5000 people. A large no. of animals including livestock, pet dogs and birds have died. On the same day 2 boilers exploded at NLC India Limited’s thermal power station at Neyveli, TN injuring 8 people. On May 6, another gas leak accident had taken place at Chhattisgarh. All these accidents took place within 24 hours and the common factor is that they all occurred when the factories were being prepared for opening after the Covid 19 lockdown. Lack of maintenance practices during the lockdown and shortage of skilled staff seemed to be the common thread in all the accidents.[15] 

LEGAL CONSEQUENCES OF A GAS TRAGEDY

Occurred in Bhopal

On the night of December, 1984, a worst disaster was caused by the leakage of methyl isocyanate (MIC) and other toxic gases from a plant set up by the union carbide India Ltd. (UCIL) for the manufacture of pesticides, etc. in Bhopal.

This tragedy has resulted in the death of almost 3000 people staying near the plant and also people who are staying far from the plant. Serious injuries are also caused to eyes, respiratory system, damages to the fetus of pregnant women etc.

  • Criminal liability

Here, criminal liability was charged under Section 304(A), Section 336, Section 337 and Section 338 of IPC. Section 304(A) of IPC deals with the causing of death by negligence. Section 336, 337 and 338 of IPC deals with the offences of endangering the life and personal safety of others.

The whole disaster was caused due to lack of reasonable care. The Council of Scientific and Industrial Research (CSIR) noticed that, instead of storing MIC in a stainless steel drum, it was stored in a tank. Lack of alarming instruments and lack of necessary facilities are the main reason which led to the accident.

  • Principle of Absolute liability

The absolute liability was the main issue faced by the Bhopal gas tragedy. And this issue has been explained in a case of M.C. Mehta v. Union of India.[16] The Supreme Court had created this rule for the harm caused by dangerous substances. The principle of absolute liability states that, if an enterprise is engaged in an dangerous or hazardous industry which hold a possible threat to the health and safety of the persons working in the factory and residing in the surrounding areas or far from that has an absolute duty that no harm should be caused to any one of the human beings residing there. And if any harm occurred due to this industry and their activities, the enterprise will be absolutely liable and they have to compensate for the victims. Even if the enterprise has taken any reasonable care, they have to pay the compensation.[17]

There are several cases in which the principle of absolute liability was applied. They are: – Indian council for Enviro-legal action v. Union of India[18],Klaus Mittelbachert v. East India Hotels Ltd[19]

 Occurred in Visakhapatnam

On the dreadful night of May 6, 2020, one more disaster struck the people residing in Gopalapatnam which is near Visakhapatnam, Andhra Pradesh. In no time almost 13 people were reported as dead and thousands of people were hospitalized critically.

The leak was found from LG Polymers India Limited. It was a manufacturing industry. It manufactures polystyrene which is a type of plastics used in consumer products like toys and appliances. The gas leaked from the industry was styrene. There are some gases which need to be stored in a cold temperature. Styrene was also such a type of gas which needed to be stored at a cold temperature. The industry was shut down by the reason of lockdown, that is another pandemic faced all over the world. It was reported that, due to the chemical reaction the heat was produced inside the tank as a result of which gas leaked. The air is contaminated by this toxic gas which leads to several respiratory problems and other kinds of dangerous diseases.

National disaster response force, national green tribunal, national human rights committee, etc. have taken suo moto cognizance of the case and provided notices to the central and the state governments to investigate the accident.

There are some legal connections in these accidents. They are as follows:- 

  • Criminal liability

LG Polymers dealt with the dangerous gas like styrene, and owed a high duty of care towards the public. The factor of criminal liability is a major element in this disaster Because the owners have the responsibilities to take care towards the public. Here, owners have made negligence and recklessness. Precautions are to be taken when the plant is going to be shut for a long period because of Covid 19 lockdown. The owner’s must have taken necessary precautions to maintain the temperature of the gas. But they didn’t do so. So that, the owners have been charged under Section 304 of IPC culpable homicide not amounting to murder and Section 304(A) of IPC causing death by negligence. They are also liable under Sections 336, 337, 338 of IPC which deals with the offences of threatening or risking the life and personal safety of others. Then they charged under Section 278 of IPC, vitiating the atmosphere to make it noxious to health; Section 284 of IPC, negligent conduct of poisonous substances; Section 285 of IPC, negligently conducting fire or any combustible matter.

  • Tortious liability

In tortious liability, there is absolute liability and strict liability. After the Bhopal gas tragedy, one more accident took place in Delhi where there was a leakage of Oleum gas which led to the death of a person resulting in the principle of absolute liability. And there is an exception in that case, in the rule of strict liability. Here, absolute liability makes the enterprise to pay the compensation to the victims and such liability is not subjected to any of the exceptions which operates the tortious liability under the rule of in strict liability (Rylands v. Fletcher),[20] The owners of the company will argue that all these circumstances were not under their control due to lockdown but that doesn’t have any value under this principle and the company or a firm cannot run off from these liability by showing that it has taken reasonable care and there was no negligence on its part.    

COMPENSATION FOR THE VICTIMS

Government passed a series of prescribed penalties and after those safeguards for these calamities. These include the Environmental protection act, 1986, the Public insurance liability act, 1991, and the National green tribunal act, 2010.

Public Insurance Liability Act, 1991

Under this act, the owners of the companies need to take insurance policies compulsorily within one year of handling those dangerous things. Within five years of the incident, a petition or an appeal for claim for relief can be filed before the collector. After the inquiry collector will direct the company to pay the amount decided by him. Here, the LG Polyesters, have taken an insurance of Rs. Five crores and additional top-up of Rs. Five crores. And these amounts can be paid to the victims of the accident. Moreover, an environment relief fund can be given to the victims which is created by the central government under.

Public insurance liability act came to force after the commencement of Bhopal gas tragedy.

The National Green Tribunal Act, 2010

According to the national green tribunal act, 2010, the right to a healthy environment is a part of the right to life under Article 21 of constitution of India. This tribunal orders relief and gives compensation to the victims of any environmental damages and any accident occurred while handling dangerous substances. Relief given by this act is an additional relief to the public insurance liability act. No civil courts entertain the cases in which the tribunal is competent to hear. 

Environmental Protection Act, 1986 

Environment protection act was laid down after the Bhopal gas tragedy. The act emerged in1986. To protect the environment, the environment protection act takes all the necessary measures and it is an important act. To store the hazardous or dangerous chemicals and to maintain the chemical plants, there are some strict procedures to be followed.[21]

MEASURES TO PREVENT THE ENVIRONMENTAL DISASTERS

Recently, toxic gas leakage from LG polymers factory in Visakhapatnam, killed so many people and around 5000 were hospitalized critically. Not only in Visakhapatnam thirty years back there was a gas tragedy which resulted in deaths and people are still suffering from this issue which has caused too many health problems like respiratory damages etc. Even new born babies are suffering from it. India is a victim of no. of gas tragedy. All these are caused due to the negligence of human beings. There are some safety measures in the factory. But none of that has worked. The company vacated the factory site. But the land is contaminated due to this incident. No one has been cleaned and still there are poor families who are staying near to that land.

Therefore, to prevent all these environmental disasters including the gas tragedy there are some methods. Natural disasters are unpredictable whereas environmental disasters are also unpredictable but still the reason for that is we human beings. Knowingly or unknowingly we human beings are responsible for that.

All these gas tragedies or chemical disasters can be prevented if the risks are identified earlier which means before starting the factory. To prevent this, it is necessary to take a merged struggle from the private sector and society. There are some measures. They are:-

Develop some policies to ensure that industries operate according to the technical and safety standards. Distributing some risk assessment and monitoring. Most of all it’s important to be attached to environmental norms. Look after the environment safely and take care of your health seriously. Promote DO-NO-HARM industrial development. Also do sustainable development programs.

Both government and factory officials have to take care of all the accidents that occur and prevent those to occur henceforth. Measures that should have taken enough to control such situation include:- 

  • The government should employ chemical intellectuals specifically to monitor or guide factories.
  • Factories should employ only skilled workers for risky depts.
  • Make sure that the factory is abided of all norms and regulations.
  • License should be cancelled swiftly of those factories who do not respect the norms.
  • The periphery of the factory should be confined and the designity should be planted with trees.
  • Alarms should be installed to alert people of the vicinity in case of any accidents.

And by doing all those things we can prevent the tragedies and protect our environment.[22]    

CONCLUSIONS  

India has faced the worst industrial disasters. Gas tragedies are one of the main disasters in our country, due to this thousands and thousands of peoples die immediately and due to this victims of this disaster suffer from dangerous diseases like blindness, respiratory problems etc. Not only humans, even animals, birds also suffer from these. In this paper, it highlights the major industrial disasters taking place in India focusing on gas tragedy since 1984. These kinds of disasters occur due to the negligence of humans itself and it has been noted that, vizag gas tragedy 2020 was occurred during the period of another major pandemic that is, COVID-19. The victims of vizag gas tragedy reside upto a 5-kilometres radius which will make them vulnerable to breathing the contaminated air. As a result, their immunity might be weak which will make them a possible victim of the COVID-19. As I said before, carelessness of the industrial owners makes all these gas tragedies. So in order to mention their liabilities there are some legal consequences. Legal consequences include criminal and tortious liability. Various compensations are also given to the victims. Several prevention measures are also taken place to control all these disasters. To cover up the inadequacies in medical care, several studies suggested the necessity for long-term monitoring of the affected community and use of appropriate methods of investigation that include well-designed cohort studies for such conditions, characterization of personal exposure and accident analysis to determine the possible components of toxic cloud as the investigators have noted several clinical and epidemiological inadequacies, including poor study design, bias and inaccurate exposure classification.

Hence, by considering all these strategies we can provide necessary things to the victims of the disaster and  can control the disasters which are caused due to the negligence of human beings.


[1] Cullinan, P., Acquilla, S. D., & Dhara, V. R. (1996). Long term morbidity in survivors of the 1984 Bhopal gas leak. National Medical Journal of India, 9, 5–9.

[2] Mishra, P. K., Samarth, R. M., Pathak, N., Jain, S. K., Banerjee, S., & Maudar, K. K. (2009). Bhopal gas tragedy: review of clinical and experimental findings after 25 years. International Journal of Occupational Medicine and Environmental Health, 22(3), 193.

[3] De, S. (2012). Retrospective analysis of lung function abnormalities of Bhopal gas tragedy affected the population. The Indian Journal of Medical Research, 135(2), 193.

[4] Cullinan, P., Acquilla, S., & Dhara, V. R. (1997). Respiratory morbidity 10 years after the Union Carbide gas leak at Bhopal: a cross sectional survey. Bmj, 314 (7077), 338.

[5] Ghosh, B. B., Sengupta, S., Roy, A., Maity, S., Ghosh, S., Talukder, G., & Sharma, A. (1990). Cytogenetic studies in human populations exposed to gas leak at Bhopal, India. Environmental Health Perspectives, 86, 323–326.

[6]Anjana, N. S., Nair, M. V. H., Sajith, K. S., Amarnath, A., & Indu, I. (2018). Accidental release of ammonia from a storage tank and the effects of atmosphere on the affected area using ALOHA. Indian Journal of Scientific Research, 1–8.

[7] (Broughton, 2005)Broughton, E. (2005). The Bhopal disaster and its aftermath: a review. Environmental Health, 4(1), 1–6.

[8] Varma, D. R., & Guest, I. (1993). The Bhopal accident and methyl isocyanate toxicity. Journal of Toxicology and Environmental Health, Part A Current Issues, 40(4), 513–529.

[9] Study impact of Tughlakabad gas leak: NGT to AIIMS panel, DNA INDIA (May, 16, 2017), https://www.dnaindia.com/india/report-study-impact-of-tughlakabad-gas-leak-ngt-to-aiims-panel-2439552 

[10] Chlorine gas leak on Belur outskirts, THE HINDU (May 16, 2017), https://www.google.com/amp/s/www.thehindu.com/news/national/karnataka/chlorine-gas-leak-on-belur-outskirts/article18464684.ece/amp/.   

[11] Stephanie Roker, Mangalore-Hassan-Mysore-Sollur gas pipeline leak, WORLD PIPELINES (Nov, 17, 2016), https://www.google.com/amp/s/www.worldpipelines.com/project-news/17112016/mangalore-hassan-mysore-sollur-gas-pipeline-leak/amp/.   

[12] Kanpur: Ammonia gas leak causes explosion in cold storage; five killed, several still trapped, FIRSTPOST (Mar 15, 2017), https://www.google.com/amp/www.firstpost.com/india/kanpur-ammonia-gas-leak-causes-explosion-in-cold-storage-five-killed-several-still-trapped-3335870.html/amp.  

[13] Sreenivas Janyala, Gail pipeline explosion: ‘Ignored’ gas leak kills 15 in Andhra Pradesh, FINANCIAL EXPRESS (June, 28, 2014), https://www.financialexpress.com/archive/gail-pipeline-explosion-ignored-gas-leak-kills-15-in-andhra-pradesh/1264816/.  

[14] The ghastly accident at Bhilai steel plant: An investigative Report, GROUNDXERO (April, 16, 2019), https://www.groundxero.in/2019/04/16/the-ghastly-accident-at-bhilai-steel-plant-an-investigative-report/.

[15] “et al’’, The complete story of vizag gas leak, DOWNTOEARTH, https://www.downtoearth.org.in/dte-infographics/vizag-gas-leak/index.html.

[16] M.C. Mehta v. Union of India. (1987 SCC (1) 819, AIR 1987 965).

[17] Deepika Nuals, Legal aspects of the Bhopal gas tragedy, LEGAL SERVICE INDIA, www.legalservicesindia.com/article/33/Legal-Aspects-of-the-bhopal-gas-tragedy.html.  

[18] Enviro-Legal action v. union of India (1996 AIR 1446, 1996 SCC (3) 212).

[19] Klaus Mittelbachert v. East India Hotels (1999 AC 287).

[20] Rylands v. Fletcher [1868] UKHL 1, (1868) LR 3 HL 330.

[21] Adithi Rao, Legal consequences of a disaster during a pandemic, THELEAFLET ( May, 09, 2020), https://www.theleaflet.in/legal-consequences-of-a-disaster-during-a-pandemic/#

[22] Adriana Jordanova Damianova, How to prevent another Bhopal, WORLD ECONOMIC FORUM (Dec, 5, 2014), https://www.weforum.org/agenda/2014/12/how-to-prevent-another-bhopal/.    


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