# M.C. MElITA & ANR. E'l'C v. UNION OF INDIA & lU situated in approxillately 76 acru and they are surrounded by thicltly populated colonies Inch 11 Punjabi Bagh, Weat Patel Nagar, Karampura, Asholt .. Vihar, · Trinqar, Shaetri Nagar and within a radius of 3 • kil011etrea frOll thil complex there is a population of approrl- ~ utely 200,000. The cau1tic chlorine plant wu coraissioned in the year 1949 and it has a strength of about 263 employees' includiag executives, aupenisora, staff and work.era. In the Wike of the Bhopal gas tragedy realising the lluardoue character of eau1tic chlorine plant of Shrirma, the Labour Mini1try of the Government of India cOlllliasioned •tecbnica•, a f ira of couul tatl, Scientists and Engineer&• of the United Xiaidoa who set out the areas of concern and potential probl-, in their Report. Thereafter, the Dehi~'" Adliiautration coutituted an Expert Comittee ·under the Chair.a.hip of Mr.· llanohan Singh. This Coiiimittee Jllede M.C. MEHTA v. U.O.I. 313 ~l various recmmiendations in regard to safety and pollution control measures with a view to minillising ltasard to the workmen and the public. On December 4, 1985, a major leakage of oleua gas toolt place frOll one of the units of Shri Ru and this lealtags . affected a large number of persons, both aongst the workmen and the public and an Advocate practising in tlte Tis .Basari Court died on account of inltalation of oleo11 gas. Thia leakage resulted. from the borsting of tlte tank containing oleum gas aa a result of the collapse of the structure on which it vu 1111unted and it· created a scare uongst tlte people residing in that ares. Hardly had the pe0ple got out of the sltoclt of this disaster, when within two days, another leakage, though thia time a minor one toolt place as a result of escape of oleum gaa froa the joints of a. pipe. The 1-diste response of the Delhi Adminilitration to these two leakages was the ulting of, an order dated 6th December '85 by the District Magistrate Delhi, under sub-section (1) of section 133 of tlte Code of Criainal "'· Procedure, directing and requiring Shriraa within two' days from the date of issue of the order to cease carrying on the occupation of 1111111ufacturing and processing ltasardona and letltal chemicals and gases ilicluding chlorine, oleua, auperchlorine, phosphate etc. at their establishllent in Delhi and within 7 days to remove such chemical• and gases from the said place and not again to lteep or store tltea at the s- place or to appear on 17th December 85 in ~he Court of District Magistrate, Delhi to allow cause why the order should not .be enforced. In the meantime, the "Agarwal Coami~tee" appointed •• by the Supreme Court . visited the caustic chlorine plant and submitted a Report in which it pointed · out various inadequacies in the plant and expressed the opinion that it waa not possible to eliminate ltasard to the public so long as the plant remained at.the present location. Since there were conflicting opinions put forward in regard to the question whether the caustic chlorine plant should be ## Text _Characters 0–39,234 of 86,406. This is a partial read: ask again with offset=39234 for what follows._ A B c D E F G H 312 M.C. MElITA & ANR. E'l'C. v. UNION OF INDIA & lU situated in approxillately 76 acru and they are surrounded by thicltly populated colonies Inch 11 Punjabi Bagh, Weat Patel Nagar, Karampura, Asholt .. Vihar, · Trinqar, Shaetri Nagar and within a radius of 3 • kil011etrea frOll thil complex there is a population of approrl- ~ utely 200,000. The cau1tic chlorine plant wu coraissioned in the year 1949 and it has a strength of about 263 employees' includiag executives, aupenisora, staff and work.era. In the Wike of the Bhopal gas tragedy realising the lluardoue character of eau1tic chlorine plant of Shrirma, the Labour Mini1try of the Government of India cOlllliasioned •tecbnica•, a f ira of couul tatl, Scientists and Engineer&• of the United Xiaidoa who set out the areas of concern and potential probl-, in their Report. Thereafter, the Dehi~'" Adliiautration coutituted an Expert Comittee ·under the Chair.a.hip of Mr.· llanohan Singh. This Coiiimittee Jllede M.C. MEHTA v. U.O.I. 313 ~l various recmmiendations in regard to safety and pollution control measures with a view to minillising ltasard to the workmen and the public. On December 4, 1985, a major leakage of oleua gas toolt place frOll one of the units of Shri Ru and this lealtags . affected a large number of persons, both aongst the workmen and the public and an Advocate practising in tlte Tis .Basari Court died on account of inltalation of oleo11 gas. Thia leakage resulted. from the borsting of tlte tank containing oleum gas aa a result of the collapse of the structure on which it vu 1111unted and it· created a scare uongst tlte people residing in that ares. Hardly had the pe0ple got out of the sltoclt of this disaster, when within two days, another leakage, though thia time a minor one toolt place as a result of escape of oleum gaa froa the joints of a. pipe. The 1-diste response of the Delhi Adminilitration to these two leakages was the ulting of, an order dated 6th December '85 by the District Magistrate Delhi, under sub-section (1) of section 133 of tlte Code of Criainal "'· Procedure, directing and requiring Shriraa within two' days from the date of issue of the order to cease carrying on the occupation of 1111111ufacturing and processing ltasardona and letltal chemicals and gases ilicluding chlorine, oleua, auperchlorine, phosphate etc. at their establishllent in Delhi and within 7 days to remove such chemical• and gases from the said place and not again to lteep or store tltea at the s- place or to appear on 17th December 85 in ~he Court of District Magistrate, Delhi to allow cause why the order should not .be enforced. In the meantime, the "Agarwal Coami~tee" appointed •• by the Supreme Court . visited the caustic chlorine plant and submitted a Report in which it pointed · out various inadequacies in the plant and expressed the opinion that it waa not possible to eliminate ltasard to the public so long as the plant remained at.the present location. Since there were conflicting opinions put forward in regard to the question whether the caustic chlorine plant should be allowed to be restarted withont any real ltasard or . risk to the woria.en and the public at large, another Expert Comrlttee called "Nilay Chondhary Coamittee• vu constituted by the Supreme Court, by its order dated 18th .Decaaber 85 • . -I This Comittee visited the caustic . chlorine plant on Deceaber · 28, 1985 and after considering Dr. Slater, llanaohan Singh Coaitt..,, Agarwal Comrlttee and after bearing the parties A B c D E F G H A B c D E F G H 314 SUPREME COURT REPORTS [19861 1 s.c.R. ude a r:!pOrt setting·· out 14 rece>mEDdatiou which in its opinion .rere required to be COllpliecl with by the unagemnt in order to minimise the hazards due to possible chlorine leak. The Committee also pointed out thst it was in ogre-nt with the rec~ations ude in the l!eport of the llmmohan Singh eo.!ttee which were exhaustive in nature and obviously the re~tions ude by it in its l!eport were suppleMlltary reco-ndation in addition to those contained in Maimohan Singh Collllittee's Report. In addition to these Comittees, the Lt. Governor of Delhi also appointed an Expert Comittee called the •Seturaan Collllittee• which submitted its l!eport on 3rd Jannary, 1986. While these proceedings were going on before the Court, an order dated 7th December 85 was issued by the Inspector of Factories, Delhi in exercise of the poVer conferred under section 40, sulMlection (2) of the Factories Act, 1948, prohibiting Shrir1111 frOll using caustic chlorine and sulphuric acid plants till adequate · safety •asures are adopted and iminent danger to human life ia eliminated. Soon thereafte.r, on December 13, 1985 a show cause notice was issued by the Assistant Comissioner (Factories) of the ltJnicipal Corporatiop. of Delhi, calling upon Shrir1111 to show cause as to why action for revocation of its licence should not be taken under section 430, sub-section (3) of the Delhi Municipal Corporation Act, 1957 for violation of the terms and conditions of the licence. Shriram showed cause, by its letter dated 23rd December' 85, against the proposed cancellation of its licence but by an order dated 24th December' 85, the Assistant eo.tssioner (Factories) directed Shriraa to stop industrial use of the premises at which the chlorine caustic plant is located. The result is that unless these two orders - one dated 7th December 1985 and the other dated 24th December 1985 - are vacated or suspended, Shrir1111 cannot restart ths caust le chlorine plant. Hence the Shrirllll's Writ Petition challenging the said two orders. Suspending the operation of the two ordera ad-interill to enable Shriram to restart the plants for unufacture of caustic chlorine including its by products, the Court laid down as 11any as eleven conditions, and •• j M.C •. MEHTA v. u.o.r. 315 mru>: 1. All Expert Collllllittees are unanimous in their view that by adopting proper and adequate safety measures, the element of risk to the workmen and the public can . only be minimised, but it cannot be totally eliminated. The general concensus of opinion of all the Expert Collllllittees is that relocation of the caustic chlorine plant is the only long term solution, if hazard to the community is to be completely eliminated. lihether tile caustic chlorine plant should be directed to be shifted or relocated . at a place where there will be no hazard to the coammiW and if so, within what time-frame, is a question which will require serious consideration and a National Policy will have to be evolved by the Government for location of toxic or hazardous industries and a decision will have to be taken in regard to relocation of such industries with a view to eliminating risk to the cOlllllllllity likely to arise from the operation of such · industries. [325 B-D; 329 E-F] A B c · 1. 2 It is undoubtedly true that chlorine gas is · D -""'I' dang'erous to the life and ·health of the COtmmlllity and it . escape~ either from the storage tanks or from the filled cylinders or from any other point in the cause of production, it is likely to Sffect the health and .... 11 being of the workmen and the people in the vicinity. Both Agarwal and Manmohan Singh Colllllittees are agreed to their opinion that E chlorine is s hazardous gas and though smaller concentrations of chlorine iii the air cause only an irritation and coughing, longer concentrations whether 25 parts per million (PPM) or 40 parts per million (PPM) are likely to cause serious danger to life. However, in view of the Report of yet another Expert A Connittee (consisting of Dr. Manmohan Singh, Dr. Sharma, Prof. F P. Khanna & Shri Gharekhan) appointed for the purpose ·of ascertaining whether the various recommendations made in the earlier Reports were substantially complied with or not, aiid taking into consideration that even the restarting of the Vanaspati, refined oil plant and recovery plants like soap, glycerine and technical hard oil, not involving any health G hazard, cannot be possible unless the caustic chlorine plant is also restarted and severai other factors including the PQ""r of the Board to renew or not to renew consent orders under the Air Act. and Water Act, the balance of convenience . ~would tilt in favour of Shriram to be· allowed to restart their plants subject to certain stringent conditions. [330 G-R; H 331 C-D; 337 D-il] A B 316 SUPREME COURT REPORTS [19861 l s.c.R. 1.3 Since cases involving issues of environmental pollution, ecological destruction and conflicts over natural resources are increasingly coming up for adjudication and these cases involve assessment and evolution of scientific and technical data, it might be desirable to set up Enviornment Courts on the regional basis with.one professional Judge and two experts drawn from the Ecological Sciences Research Group keeping in view the nature of the case and the expertise required for its adjudication. There would of course be a right of appeal to this Court from the decision of the Environment Court. (345 H; 346 A-C] c ORIGINAL JURISDICTION : Writ Petition (Civil) Nos. 12739 D E of 1985' and 26 of 1986. (Under Article 32 of the Constitution of 'India) Anil B. Divan, Avadh Bihari, Danial Latifi, B. Datta, Additional Solicitor General, M.C. Mehta (Petitioner-in-person); Ravinder Narain, S. Kashwaha, D.N. Mishra, S. Sukumaran of J.B. Dadachanji & Co., Raju Ramachandran, R.D. Agarwala, C.V.S. Rao, D. Kashwaha, R.N. Poddar, R. Mohan, B.P. Maheshwari, M.C. Dua, Ravinder Bana, A.K. Nauriya, R.S. Sodhi and Ms. Kitty Kumaramanglam for the appearing parties. The Judgment of the Court was delivered by BllAQlATI, C.J. Writ Petition No. 12739 of 1985 which has been brought by way of public interest litigation talses some seminal questions concerning the true scope and alllbit of .Arts. F , 21 and 32 of the Constitution, the principles and norms for ~ determining the liability of large enterprises engaged in manufacture and sale of hazardous products, the basis on which damages in case of such liability should be quantified and whether such large enterprises should be allowed to continue to function in thickly populated areas and if they are G permitted so to function, what measures 1111st be taken for the purpose of reducing to a minimum the hazard to the workmen and the community living in the neighbourhood. These questions which have been raised by the petitioner are questions of the greatest importance particularly since, following upon the leakage of MIC gas from the Union Carbide Plant in Bhopal, )<- - H lawyers, judges and jurists are considerably exercised as to what controls, whether by way of relocation or by way of M,C, MEHTA v. U.O.I. [BllAGWATI, C,J.] 317 _..\ ·installation of adequate safety devices, need to be imposed on Corporations employing hazardous technology and producing toxic or dangerous ·substances and if any liquid or gas escapes which is injurious to the workmen and the people living in the surrounding areas, on account of negligence or otherwise, what is the extent of liability of such Corporations and what remedies can be devised for enforcing such liability with a view to securing payment of damages to the persons affected by such leakage of liquid or gas. These questions arise in the -1. present case s irice on 4th and 6th Decemtier, 1985, there was admittedly leakage of oleum gas from one of the units of . Shriram Foods and Fertiliser· Industries and as a result of such leakage, several persons were affected and according to the petitioner and the Delhi Bar Association, one Advocate practising in the Tis Hazari Courts died. We propose to hear detailed arguments on these questions at a later date. But one pressing issue which has to be decided by us immediately is whether we should allow the caustic chlorine plant of Shriram --. Foods and Fertiliser Industries to be rest_arted and that is the question which we are proceeding to decide in this judgment. I Delhi Cloth Mills Ltd. is a public limited company having its registered office in Delhi. It runs an enterprise called Shriram Foods and Fertiliser Industries and this enterprise has several units engaged in the manufacture of caustic soda, chlorine, hydrochloric acid, stable bleaching powder, superphosphate, vanaspati, soap, sulphuric acid, alum anhydrous sodium sulphate, high test hypochlorite. and active •• earth. These various units 9re all set up in a single complex situated in approximately 76 acres and they are surrounded by thickly populated colonies such as Punjabi Bagh, West Patel ... Nagar, Karampura, Ashok Vihar, Tri Nager and Shastri Nager and within a redius of 3 kilometres from this complex there is population of approximately 200,000. We are concerned in this Order orily with the caustic chlorine plant. This pl~t was commissioned in the year 1949 and it has a strength of about 263 employees including executives, supervisors, staff and workers. It appears that until the Bhopal tragedy, no one .neither the management of Shriram Foods and Fertiliser Industries (hereinafter referred to as 'Shriram') not the -' Government seemed to have bothered at all about the hazardous character of caustic chlorine plant of Shriram. But, it seems· that the Bhopal disaster shook of the lethargy of everyone and A B c D E F G H A B c D E F G H 318 SUPREME COURT REPORTS [19861 1 s.c.R. triggered off a new wave of consciousness and every Government became alerted to the necessity of examining whether industries employing hazardous technology and producing dangerous coDIDOdities were equipped with proper and adequate safety and pollution control devices and whether they posed any danger to the workmen and the co1D111nity living around them. The Labour Ministry of the Government of India acco~dingly comnissioned 'Technica', a firm of Consultants, Scientist& and Engineers of United Kingdom, to visit the caustic chlorine plant of Shriram and make a report in regard to the areas of concern and potential problems relating to that plant. Dr. Slater visited the caustic chlorine plant on behalf of Technica sometime in June-July 1985 and submitted a report to the Government of India summarising the initial impressioiw f ·-.j M.C. MEHTA v. U,0,1, [BHA~ATI, C.J,) 319 dealing exclusively with the caustic chlorine plant and considerable reliance 111.lst, therefore, be placed upon it. The Manmohan Singh Committee made various recommendations in this Report in regard to safety and pollution control measures with a view to minimising hazard to the workmen and' the public and obviously the caustic chlorine plant cannot be allowed to be restarted unless these recommendations are strictly complied with by the management of .shriram. Now, on 4th December, 1985 a major leakage of oleum gas took place from one of the units of Shriram and this leakage affected a large number of persons, both amongst the workmen and the public, and, according to the petitioner, an Advocate practising in the Tis llazari Courts died on account of inhalation of oleum gas. This leakage resulted from the bursting of .the tank containing oleum gas as a result of the collapse of. the structure on which it was mounte and it created a scare amongst the people residing in that area. Hardly had. the people got out of the shock of this disaster when, within two days, another leakage, though this time a minor one, took place as a result of escape of oleum gas from the . joints of a pipe. The immediate response of the Delhi Administration to these two leakages was the making of an Order dated 6th December 1985 by the District Magistrate, Delhi Under sub-s.(l) of s.133 of the Code of Criminal Procedure, directing and requiring Shriram within two days from the date of issue of the order to cease carrying on the occupation of manufacturing and processing hazardous and lethal chemicals and gases including chlorine, oleum, super-chlorine, phosphate, etc. at their establishment in Delhi and within 7 days _to remove such chemicals and gases from the said place and not again to keep or store them at the same place or to appear · on 17th December 1985 in the court of the District Magistrate, Delhi to show cause why the order should not be enforced. When we took up the writ petitions for hearing on 7th December 1985, our attention was drawn to this order made by the District Magistrate, Delhi on 6th December 1985 and on perusing the order we pointed out the inadequ_acies in it which had the effect of virtually defeating the urgency of the action to be taken. We had earlier appointed a team of Experts. to visit the caustic chlorine plant of Shriram and to report whether the recommendations of the Manmohan Singh Committee had been carried out by the management and this team of Experts orally reported to us at the hearing on 7th December, 1985 that they A B ' c D E F G H A B c D E F G H 320 SUPREME COURT REPORTS [1986] 1 s.c.R. had been able to inspect the plant for only a couple of hours and that cursory inspection showed that msny of the recommendations of the Manmohan Singh Committee appeared to have been complied with and that too two one hundred MT tanks for storage of chlorine which constituted a major element of hazard or risk had been emptied. Since this inspection made by the team of Experts had necessarily to be very hurried and superficial on account of want of sufficient time, we adjourned the writ petition to 13th December, 1985 with a direction that the petitioner would be entitled to appoint his own team of experts who would be allowed access to the cauatic chlorine plant for the purpose of ascertaining whether the various recommendations of the Manmohan Singh Committee had been carried out or not and whether there were any other drawbaclts or deficiencies likely to endanger the lives of workmen and the public. We also, with a view to expediting adjudication of claims for compensation on behalf of the victims of oleum gas leakage, appointed the Chief Metropolitan Magistrate as the Officer before whom claims for compensation may be filed by persons affected by leakage of oleum gas in the course of the two incidents referred to above and we fixed time of four weeks within which such claim ~f compensation may be filed before the Chief Metropolitan Magistrate, Delhi. We may point out that subsequently by an Order dated 10.1.1986 we extended the time for filing of compensation claims upto January 31,1986. We also by our Orders dated 16.1.1986 and 21.1.1986 gave a further direction that those who file compensation claims before the Chief Metropolitan Magistrate, Delhi should be got examined by a team of Medical Experts and this task was entrusted to the Secretary of the Delhi State Legal Aid and Advice Board. This direction was given by us with a view to ensuring that contemporaneoua medical evidence of the injuries suffered by the claimants and of the cause of such injury should be available in support of the claims for compensation lodged by the v'-ctims of oleum gas leakage. Pursuant to the liberty given by us, the petitioner appointed an Expert Committee consisting of Dr. G.D. Agarwal, Professor T. Shivaji Rao and Shri Purkayastha. This Committee, which we. shall hereafter refer to as the 'Agarwal Committee', visited the caustic chlorine plant and submitted a Report to this Court in which it pointed out various inadequacies in \r the plant and expressed the opinion that it waa not possible M.C. MEHTA v. U.O.I. [BHAGWATI, C.J.] 321 •. to eliminate hazard to the public so long as the plant ·remained at the present location. Since there were conflicting opinions put forward before us in regard to the question whether the caustic chlorine plant should be allowed to be restarted ·without any real hazard or ris.k to the workmen and the public at large, we thought it desirable to appoint an independent team of Experts to assist us in this task. We accordingly by an Order dated 18th December, 1985 constituted a Committee of Experts consisting' of Dr. Nilay Choudhary as Chairman and Dr. Aghoranurty and Mr. R.K. Garg as Members to inspect the caustic chlorine plant and submit a report to the Court on the following three points : 1. Whether the plant can be allowed to recommence the operations in its present state and condition? 2. If not, what are the measures required to .be adopted against the hazard or possibility of leaks, expl'osion, pollution of air and water etc., for this purpose? 3. How many of the .safety devices against the above hazards and possibility exist in the plant at present and which of them, though necessary, are not installed in the pl~t. This Committee of Experts to which we shall hereafter, for the sake of convenience,, ·refer to as 'Nilay Choudhary Committee', visited the caustic chlorine plant on December 28, 1985 and after considering the Reports of Doctor Slater, Manmohan Singh Committee and Agarwal ·Committee and hearing the parties made a report to the Court setting out 14 recommendations which in its opinion were r~quired to be complied with by the management in order to minimise the hazards due to possible chlorine leak. Nilay Choudhary Committee pointed out that it was in agreement .with the recommendations made in the Report of the Manmohan Singh Committee which were exhaustive in nature and obviously the recommendations made by it in its Report were supplementary recommednations in addition to those contained in Manmohan Singh Cpmmittee's Report. We have thus two major Reports, one of Maruoohan Singh A B c D E F G H A 322 SUPREME COURT REPORTS 11986] ·1 s.c.R. Comml.thtee and thnde other of iNihlay Choudhary Committee, setting •• out t e recomme ations wh c 1111st be complied with by the management of Shriram in order to minimise the hazard or risk which the caustic chlorine plant poses to the workmen and the public. The question is whether these recommendations have been complied with by the management of Shriram, for it is B only if these recommendations have . been carried out that we can possibly consider whether the caustic chlorine plant should be allowed to be restarted. c D E F G H There is also one other report to which we 1111st refer in this connection and that is the Report made by the Expert Comml.ttee appointed by tl\e Lt. Governor of Delhi foliowing upon the leakage of oleum gas on 4th December 1985, Since the leakage of oleum gas caused' serious public concern, the Lt. Governor of Delhi constituted an Expert committee consisting of Shri N.K. Seturaman as Chairman and four other experts as members to go into the causes of spillage of oleum and its after-effects, to examine if inspection and safety procedures prescribed under the existing laws and rules were followed by Shriram, to fix responsibility for the leakage of oleum gas, to review the emergency plans and measures for containment of risk in the event of occurrence of such situations and for elminati0n of pollution, to examine any other aspects that may have a bearing on safety pollution control and hazard to the 1 public from the factory of Shriram, to make specific recommendations with a view to achieving effective pollution control and safety measures in the factory and to advise whether the factory should be shifted away from its present location in densely populated area. This Committee to which we .- shall hereafter refer to as the "Seturaman Committee" made an on the spot inspection of the site of the factory and after obtaining the required information about the plant submitted a Report on 3rd January 1986, This Report, it_ must be conceded, deals primarily with the safety procedures in the sulphuric acid plant from which there was oleum gas leakage and is not based on any indepth review and study of safety and pollution control measures in the caustic chlorine plant. But even so it does contain some obserVations which have relevance to the question whether the caustic chlorine plant poses any hazard to the coDmJnity and what steps or measures are necessary to be taken to minimise the risk ,to the people living in the ,.. vicinity. M.C. MEHTA v. u.o.I. [BHAGWATI, c.J.] 323 It is necessary at this stage to point out that whilst these proceedings were going on before the Court, an order dated 7th December 1985 was issued by the Inspector of Factories, Delhi in exercise of the power conferred under Section 40 sub-section (2) of the· Factories ·Act, 1948. The order commenced with the following recital, viz., "Whereas it has appeared to me that Cauatic chlorine plant and sulphuric acid plants are running without adequate safety measures being adopted by your management, thereby endangering the human life and safety of the workers and the public A B at large. Earlier.notices of the Labour Department C asking your management to ensure proper safety measures has not been complied with. fully; and Whereas inapite of your management '·s assurances vide letter dated 14,10,1985, on 4.12,85, non adoption of the adequate safety measures have o ~esulted in collapse of the structure on which oleum tank was munted resulting in the massive leakage of oleum cauaing fumes in the environment affecting the health and safety of a large number of residents of the Union Territory of Delhi; and Whereaa the factory is not still having adequate safety measures required for such plants." and prohibited Shriram from using the caustic chlorine and · sulphuric acid plants till adequate safety measures are 11111... adopted and imminent danger to human life is eliminated. Soon r· thereaft'er, on December 13, 1985, a show-cause notice was issued by the Assistant Commissioner (Factories) of the Municipal Corporation- of Delhi calling upon Shriram to -show-cauae as to why action for revocation of its licence should not be taken under Section 430 sub-section (3) of the Delhi Municipal Corporation Act, 1957 for violation of the terms and conditions of the licence. Shriram by its letter dated 23rd December, 1985 showed cause against the proposed cancellation of its licence but by an Order dated 24th December 1985, the Assistant Commissioner (Factories) directed Shriram to stop industrial uae of the premises at which the '