On 13 February 1996 — six months before *Vellore* — a Division Bench of the Supreme Court led by Justice B.P. Jeevan Reddy applied the absolute-liability doctrine of *Oleum Gas Leak* to five chemical units at Bichhri village in Rajasthan and operationalised the polluter-pays principle as a remediation-cost obligation. The judgment is doctrinally the antecedent to *Vellore* on polluter-pays, the first explicit reception of customary international environmental law into Indian law, and — in its 2011 execution arc — confirmed recovery of ₹37.385 crore plus interest from the polluters.
Less than a year after the Bhopal disaster, an oleum gas leak from a Shriram unit in Delhi prompted the Supreme Court — through a Constitution Bench led by Bhagwati CJ — to depart from the English strict-liability framework of Rylands v. Fletcher and to formulate a doctrine of absolute liability for enterprises engaged in hazardous activities. The judgment is the doctrinal foundation of Indian environmental and industrial liability law. A digest of the rule, why the Court declined to apply Rylands, and how the doctrine continues to operate four decades on.