T030 - Respondent

DR.
AMBEDKAR GOVERNMENT LAW COLLEGE, PUDUCHERRY PRACTICAL TRAINING-IV

ACADEMIC YEAR 2021-2024
BEFORE
THE HON’BLE SUPREME COURT OF INDIA
Original jurisdiction
UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA
PUBLIC INTEREST LITIGATION
{WRIT Petition (Civil) No. of 2024}
IN THE MATTER OF
MUKUL RASTOGI & ANR ................... PETITIONERS

VERSUS
UNION OF INDIA & ORS ........................... RESPONDENTS
[WRITTEN SUBMISSION ON BEHALF OF THE RESPODENT]
UPON SUBMISSIONS TO HON’BLE CHIEF JUSTICE & COMPANION JUSTICES OF SUPREME COURT
OF INDIA
WRITTEN SUBMISSION BEFORE

THE REGISTRY OF THE COURT ON / / 2024
Counsel for Respondent
D.VASUKI (Reg.No:21LT0056)
TABLE OF CONTENTS
LIST OF ABBREVATIONS ................................................................................................... 3
INDEX OF AUTHORITIES .................................................................................................. 4
Cases Cited… ................................................................................................................. 4
Statutes, Acts and Rules ................................................................................................... 4
Books and Commentaries .................................................................................................4
Legal Database ................................................................................................................. 4
STATEMENT OF JURISDICTION ......................................................................................5
STATEMENT OF FACTS ...................................................................................................... 7
ISSUES RAISED… ............................................................................................................... 9
SUMMARY OF ARGUMENTS ............................................................................................ 10
ARGUMENTS ADVANCED................................................................................................ 13
PRAYER................................................................................................................................ 22
2
MEMORANDUM ON BEHALF OF THE RESPONDENTS
LIST OF ABBREVATIONS
S.No. ABBREVIATIONS EXPANSION
1. & And
2. AIR All India Reporter
Anr Another
3.
4. Art Article
5. Crl Criminal
6. Cr.P.C Code of Criminal Procedure
7. Ed. Edition
8. EPA Environmental Protection Act
9. Etc., Et Cetra
10. i.e., That is
11. Hon’ble Honourable
12. No. Number
13. Ors. Others
14. IPC Indian Penal Code
15. Pg. Page
16. SC Supreme Court
17. SCC Supreme Court Cases
18. Sec Section
19. UOI Union of India
20. u/s Under section
21. Vol Volume

22. Vs. Versus
3
INDEX OF AUTHORITIES
CASES CITED
1. Rylands v. Fletcher (1868)
2. M.C. Mehta v. Union of India (1987)
3. Subhash Kumar v. State of Bihar (1991)
4. Municipal Corporation of Delhi v. Association of Victims of Uphaar Tragedy (2011)
5. M.C. Mehta v. Union of India (1987)
STATUTES, ACTS AND RULES
6. The Constitution of India, 1950

7. The Code of Criminal Procedure, 1973
8. The Indian Penal Code, 1860
BOOKS AND COMMENTARIES
1. V.N. Shukla, Constitution of India, (12th Ed, 2016)

2. B.M. Gandhi, Indian Penal Code, (4th Ed, 2017)
3. M.P. Jain, Indian Constitutional Law, (6th Ed, 2010)
4. Durga Das Basu, Shorter Constitution Of India, (14th Ed, 2009)
5. S.N. Misra, The Code Of Criminal Procedure Code, (23rd Ed, 2020)
LEGAL DATABASE
1. https://www.scconline.com/
2. https://www.manupatrafast.com/
3. https://indiankanoon.org/
4. https://www.jstor.org/
4
STATEMENT OF JURISDICTION
1. The Respondents humbly submits this memorandum before the Hon’ble Supreme Court
India under Articles of the Constitution:
Article 21: Guarantees the right to life and personal liberty.

Article 32: Provides for the right to Constitutional remedies, empowering individuals to
directly approach the Supreme Court for enforcement of fundamental rights.
2. Acts and Sections:

Environmental Protection Act, 1986:
Section 3: Empowers the Central Government to take measures to protect and improve
environmental quality.
Section 15: Imposes a duty on industries to take necessary measures to prevent
environmental pollution.
Code of Criminal Procedure (CrPC):
Section 133: Empowers magistrates to issue orders for the abatement of nuisances, including
activities endangering public health or safety.
Water (Prevention and Control of Pollution) Act, 1974:
Section 24: Prohibits the discharge of pollutants into water bodies without prior consent from
the Pollution Control Board.
Air (Prevention and Control of Pollution) Act, 1981:
Section 21: Imposes restrictions on the emission of air pollutants from industries.
Factories Act, 1948:
Section 21: Imposes obligations on factory owners to ensure the health and safety of workers
and neighboring communities.
3. Jurisdiction:
The Supreme Court of India has jurisdiction over matters related to the enforcement of
fundamental rights under Article 32 of the Constitution.
Additionally, under Article 131, the Supreme Court has jurisdiction over disputes between
the Government of India and one or more States, or between two or more States.
5
4. Orders:
Order issued by the magistrate under Section 133 of the Code of Criminal Procedure,
requiring Coromandel Garden International to cease its manufacturing and processing of
hazardous chemicals and gases, including chlorine and nitrous dioxide, and to remove such
substances from the facility within seven days.
The present memorandum sets forth the Facts, Contentions and Arguments.
6
STATEMENT OF FACTS
In Kanheri Nagar, a densely populated area in Mumbai, stands the Coromandel Garden
International, a notable food and fertilizer factory renowned for producing items such as hard
technical oil, glycerine soaps, and other petroleum products. The factory, nestled amidst the
thick urban fabric, operates a plant dealing with chlorine and sulphuric acid. Concerns about
the safety of this operation prompted Mukul Rastogi, a dedicated social activist lawyer, to file
a writ petition before the esteemed Supreme Court. Rastogi urged for the closure and
relocation of the Coromandel Garden International's plant to a safer locale, citing the dire
need to protect the health and security of the densely populated neighborhood.
Despite Rastogi's petition pending before the court, the Supreme Court, in a provisional
decision, permitted the plant to resume its operations while awaiting a final judgment on the
matter. Unfortunately, during the process of restarting the plant, a grave incident unfolded. A
leak of nitrous dioxide gas from one of the plant's units resulted in significant harm to the
local residents. Tragically, among the casualties was a lawyer practicing in the metropolitan
court, who succumbed to the inhalation of the toxic gas.
As the community struggled to recover from this devastating tragedy, another alarming event
unfolded within a mere two days. This time, a minor leak occurred due to the escape of
nitrous dioxide gas from pipe joints. The consecutive gas leaks shook the community,
prompting swift legal action. The Mumbai Legal Aid & Advice Board, along with the
Mumbai Bar Association, swiftly moved to file claims for compensation on behalf of those
who had suffered harm due to the gas leaks.
In response to the escalating crisis, the Mumbai administration invoked its authority under
Sub section (1) of Section 133 of the Code of Criminal Procedure. A magistrate issued an
order mandating Coromandel Garden International to halt its manufacturing and processing
of hazardous chemicals and gases, including chlorine and nitrous dioxide. The order
demanded the removal of such substances from the facility within seven days, with strict
instructions to refrain from storing them in the same location or face legal repercussions.
However, despite these legal measures, the Supreme Court opted to refer the case to a larger
bench. The decision was made due to the significant legal questions raised, particularly
7
concerning the interpretation of constitutional provisions, specifically Articles 21 and 32.
These articles are crucial in assessing whether a writ, coupled with compensation, would be
granted to address the grievances of the affected individuals. Thus, amidst a backdrop of
tragedy and legal complexity, the case of Mukul Rastogi versus Coromandel Garden
International stands as a test of justice and accountability in safeguarding fundamental rights
amidst industrial hazards.
8
ISSUES RAISED
ISSUE 1
1. WHETHER COROMANDEL GARDEN INTERNATIONAL BREACHED ITS DUTY OF CARE

TOWARDS THE RESIDENTS OF KANHERI NAGAR BY FAILING TO PREVENT THE GAS
LEAKS?
ISSUE 2
2. WHETHER THE CONTINUED OPERATION OF THE CHEMICAL PLANT INFRINGES

UPON THE FUNDAMENTAL RIGHT TO LIFE GUARANTEED UNDER ARTICLE 21 OF THE
INDIAN CONSTITUTION?
ISSUE 3
3. WHETHER THE ORDER ISSUED BY THE MAGISTRATE, REQUIRING COROMANDEL
GARDEN INTERNATIONAL TO CEASE ITS MANUFACTURING ACTIVITIES, IS
ENFORCEABLE AND SUFFICIENT TO MITIGATE THE RISKS POSED BY THE PLANT?
ISSUE 4
4. WHETHER THE AFFECTED INDIVIDUALS ARE ENTITLED TO ADEQUATE REMEDIES,

INCLUDING COMPENSATION AND REHABILITATION, FOR THE HARM CAUSED BY
THE GAS LEAKS?
9
SUMMARY OF ARGUMENTS
1. WHETHER COROMANDEL GARDEN INTERNATIONAL BREACHED ITS DUTY

OF CARE TOWARDS THE RESIDENTS OF KANHERI NAGAR BY FAILING TO
PREVENT THE GAS LEAKS?
Coromandel Garden International has consistently adhered to all relevant regulations and
standards governing the operation of its chemical plant. The company has invested
substantial resources in ensuring compliance with environmental and industrial safety laws to
mitigate risks to public health and safety.
The company has implemented comprehensive safety measures and protocols to prevent
accidents and minimize the likelihood of gas leaks. Regular inspections, maintenance checks,
and employee training programs are conducted to uphold the highest standards of safety in
plant operations.
The gas leaks that occurred were unforeseeable and occurred despite the implementation of
stringent safety measures. The company could not have reasonably anticipated the specific
circumstances leading to the leaks, and it acted promptly to address the incidents and mitigate
their impact on the community.
Upon detection of the gas leaks, Coromandel Garden International promptly initiated
response and containment measures to minimize harm to the residents of Kanheri Nagar. The
company collaborated with local authorities and emergency responders to ensure the safety
and well-being of the affected individuals.
It is essential to consider any contributory negligence on the part of the residents of Kanheri
Nagar, such as failure to adhere to safety protocols or unauthorized entry into restricted areas.
The company cannot be held solely responsible for the consequences of actions beyond its
control.
10
Coromandel Garden International maintains an active engagement with the local community
and endeavors to address their concerns regarding plant operations. The company is
committed to transparency and dialogue, and it seeks to foster a cooperative relationship with
residents to ensure mutual understanding and trust.
Coromandel Garden International affirms its unwavering commitment to the safety and well-
being of the residents of Kanheri Nagar. While the gas leaks were regrettable, they were
isolated incidents that occurred despite the company's best efforts to prevent them.
Coromandel Garden International remains dedicated to continuous improvement and
proactive measures to uphold its duty of care to the community.
2. WHETHER THE CONTINUED OPERATION OF THE CHEMICAL PLANT

INFRINGES UPON THE FUNDAMENTAL RIGHT TO LIFE GUARANTEED
UNDER ARTICLE 21 OF THE INDIAN CONSTITUTION?
It is humbly submitted that in response to the claim that the continued operation of the
chemical plant infringes upon the fundamental right to life guaranteed under Article 21 of the
Indian Constitution, Coromandel Garden International asserts that its operations are
conducted in full compliance with all applicable regulations and safety standards. The
company contends that its activities are essential for economic development and the
production of vital products. Furthermore, Coromandel Garden International highlights its
commitment to environmental stewardship and community safety, implementing robust
safety measures and protocols to mitigate any potential risks. The company argues that any
inconvenience caused by its operations is outweighed by the greater public interest served by
its continued presence. Additionally, Coromandel Garden International asserts that any
adverse effects on the environment or public health are unintended and minimal, and the
company remains committed to addressing any concerns in a responsible manner. Therefore,
the respondent maintains that the continued operation of the chemical plant does not infringe
upon the fundamental right to life guaranteed under Article 21 of the Indian Constitution.
11
3. WHETHER THE ORDER ISSUED BY THE MAGISTRATE, REQUIRING
COROMANDEL GARDEN INTERNATIONAL TO CEASE ITS
MANUFACTURING ACTIVITIES, IS ENFORCEABLE AND SUFFICIENT TO
MITIGATE THE RISKS POSED BY THE PLANT?
It is humbly submitted that in response to the order issued by the magistrate requiring
Coromandel Garden International to cease its manufacturing activities, the respondent asserts
that the order is unjustified and disproportionate. Coromandel Garden International contends
that it has consistently complied with all relevant regulations and safety standards, and its
operations are crucial for economic development and the production of essential products.
The company argues that the order fails to consider the significant socio-economic impact of
halting manufacturing activities, including potential job losses and disruptions to supply
chains. Furthermore, Coromandel Garden International emphasizes its commitment to
environmental sustainability and community safety, implementing stringent safety measures
and protocols to mitigate risks associated with its operations. The respondent maintains that
the order issued by the magistrate is not enforceable and fails to adequately address the risks
posed by the plant. Instead, Coromandel Garden International advocates for a balanced
approach that prioritizes both public safety and economic stability, suggesting alternative
measures to mitigate risks while allowing for the continuation of essential manufacturing
activities.
4. WHETHER THE AFFECTED INDIVIDUALS ARE ENTITLED TO

ADEQUATE REMEDIES, INCLUDING COMPENSATION AND
REHABILITATION, FOR THE HARM CAUSED BY THE GAS LEAKS.
It is humbly submitted that in response to the claim regarding the entitlement of affected
individuals to adequate remedies for harm caused by the gas leaks, the respondent,
Coromandel Garden International, presents the following arguments. Firstly, the company
expresses sympathy for those affected by the gas leaks and acknowledges the gravity of the
situation. However, Coromandel Garden International asserts that it cannot be held solely
responsible for the incidents, as it has taken all necessary precautions to prevent such
occurrences. The respondent argues that the gas leaks were unforeseeable events and
occurred despite the implementation of stringent safety measures. Additionally, Coromandel
Garden International emphasizes the prompt response and assistance provided to the affected
individuals following the incidents. The company maintains that it has fulfilled its obligations
12
to mitigate harm and provide support to those affected. Furthermore, Coromandel Garden
International contends that any compensation or rehabilitation should be determined in
accordance with established legal principles and should consider factors such as contributory
negligence and the extent of the harm suffered. Overall, while expressing empathy for the
affected individuals, the respondent argues against blanket liability and advocates for a fair
and balanced approach to addressing their grievances.
13
ARGUMENTS ADVANCED
1. WHETHER COROMANDEL GARDEN INTERNATIONAL BREACHED ITS

DUTY OF CARE TOWARDS THE RESIDENTS OF KANHERI NAGAR BY
FAILING TO PREVENT THE GAS LEAKS?
Coromandel Garden International operated its chemical plant in compliance with all
relevant regulations and standards, including those outlined in the Environmental
Protection Act and the Factories Act. The company implemented comprehensive safety
measures and protocols to prevent accidents and ensure the well-being of the community.
The gas leaks were unforeseeable events that occurred despite the company's diligent
efforts to prevent them. Coromandel Garden International could not have reasonably
anticipated the specific circumstances leading to the leaks and took prompt action to
address the incidents.
The principle of strict liability, as established in Rylands v. Fletcher, requires the
defendant's knowledge or foreseeability of the risk. In this case, the gas leaks were
unforeseeable occurrences, and Coromandel Garden International cannot be held strictly
liable for events beyond its control.
Furthermore, M.C. Mehta v. Union of India underscores the importance of considering
factors such as foreseeability and reasonableness in determining liability for
environmental harm. Coromandel Garden International acted reasonably and responsibly
in its operations, and any harm caused by the gas leaks was unintentional and minimal
Landmark Case and Precedents:
Rylands v. Fletcher (1868): In this landmark case, the court established the principle of
strict liability for dangerous activities conducted on one's land. However, it is essential to
note that liability is contingent upon the defendant's knowledge or foreseeability of the
risk.
M.C. Mehta v. Union of India (1987): This case affirmed the duty of industries handling
hazardous substances to exercise utmost care to prevent environmental pollution and
protect public health. However, the court also emphasized the need to consider factors
such as foreseeability and reasonableness in determining liability.
1
Rylands v. Fletcher (1868)
2
M.C. Mehta v. Union of India (1987)
14
Section 21: Imposes obligations on factory owners to ensure the health and safety of
workers and neighboring communities.
Article 21 of the Indian Constitution: Guarantees the right to life and personal liberty,
encompassing the right to a safe environment
.
In conclusion, the respondent argues that Coromandel Garden International did not breach
its duty of care towards the residents of Kanheri Nagar. The company operated its
chemical plant responsibly and in compliance with relevant regulations, and the gas leaks
were unforeseeable events beyond its control. Therefore, the respondent urges the court to
dismiss the allegation of breach of duty of care against Coromandel Garden International.
15
2. WHETHER THE CONTINUED OPERATION OF THE CHEMICAL PLANT
INFRINGES UPON THE FUNDAMENTAL RIGHT TO LIFE GUARANTEED
UNDER ARTICLE 21 OF THE INDIAN CONSTITUTION.
It is humbly submitted that the counter the assertion that the continued operation of the
chemical plant infringes upon the fundamental right to life guaranteed under Article 21 of
the Indian Constitution, the respondent operates its chemical plant in compliance with all
relevant environmental regulations and standards, including those outlined in the
Environmental Protection Act and the Factories Act. The company implements
comprehensive safety measures and protocols to mitigate environmental risks and protect
public health.
The right to life under Article 21 encompasses not only the right to physical existence but
also the right to a clean and healthy environment. However, the Supreme Court, in
Subhash Kumar v. State of Bihar, recognized the need to balance environmental concerns
with economic development and societal welfare.
The continued operation of the chemical plant is essential for economic development and
the production of vital products. Halting the plant's operations would have significant
socio-economic repercussions, including job losses and disruptions to supply chains,
impacting the livelihoods of numerous individuals.
Coromandel Garden International remains committed to environmental sustainability and
community safety, actively engaging in transparent dialogue with residents and
implementing measures to mitigate environmental impacts. The company's operations are
conducted responsibly and with due consideration for the well-being of the community.
Subhash Kumar v. State of Bihar (1991): In this case, the Supreme Court held that the
right to a clean and healthy environment is an integral part of the right to life guaranteed
under Article 21. However, the court also emphasized the need to balance environmental
concerns with economic development and societal welfare.
3
Subhash Kumar v. State of Bihar (1991)
16
Section 3: Empowers the Central Government to take measures to protect and improve
environmental quality.
encompassing the right to a clean and healthy environment.
In conclusion, the respondent argues that the continued operation of the chemical plant
does not infringe upon the fundamental right to life guaranteed under Article 21 of the
Indian Constitution. Coromandel Garden International operates its plant in compliance
with all relevant regulations, and its activities are essential for economic development and
societal welfare. Therefore, the respondent urges the court to dismiss the assertion of
infringement of the fundamental right to life.
17
3. WHETHER THE ORDER ISSUED BY THE MAGISTRATE, REQUIRING
COROMANDEL GARDEN INTERNATIONAL TO CEASE ITS
MANUFACTURING ACTIVITIES, IS ENFORCEABLE AND SUFFICIENT
TO MITIGATE THE RISKS POSED BY THE PLANT?
It is humbly submitted that the Hon'ble supreme court’s decision is to challenge the
enforceability and sufficiency of the order issued by the magistrate requiring Coromandel
Garden International to cease its manufacturing activities.
The order issued by the magistrate to cease manufacturing activities at Coromandel
Garden International's plant is a drastic measure with significant socio-economic
implications. It jeopardizes the livelihoods of numerous individuals employed by the
company and disrupts vital supply chains, potentially exacerbating economic hardships.
While acknowledging the importance of safeguarding public safety, it is crucial to ensure
that the scope and duration of the order are proportionate to the risks posed by the plant's
operations. The order fails to consider alternative measures that could mitigate risks while
allowing for the continuation of essential manufacturing activities.
Coromandel Garden International has a vested interest in maintaining environmental
sustainability and community safety. The company has implemented comprehensive
safety measures and protocols to mitigate risks associated with its operations,
demonstrating a commitment to responsible conduct.
The order issued by the magistrate may not be enforceable or practical in addressing the
risks posed by the plant. It overlooks the possibility of implementing targeted remedial
measures to address specific concerns while allowing for the continued operation of
essential manufacturing activities.
In light of the principles established in Municipal Corporation of Delhi v. Association of
Victims of Uphaar Tragedy, it is imperative to strike a balance between protecting public
safety and preserving economic stability. The order issued by the magistrate may be
overly restrictive and may require reconsideration in light of these principles.
18
Municipal Corporation of Delhi v. Association of Victims of Uphaar Tragedy (2011): In
this case, the Supreme Court emphasized the importance of enforcing orders issued for
the prevention of hazards or nuisances, particularly those endangering public safety.
However, the court also acknowledged the need for proportionality in determining the
scope and duration of such orders.
Code of Criminal Procedure (CrPC):
Section 133: Empowers magistrates to issue orders for the abatement of nuisances,
including activities endangering public health or safety.
encompassing the right to a safe environment.
In conclusion, the respondent argues that the order issued by the magistrate requiring
Coromandel Garden International to cease its manufacturing activities may not be
enforceable or sufficient to mitigate the risks posed by the plant. The respondent urges the
court to consider alternative measures that strike a balance between public safety and
economic stability while addressing concerns related to the plant's operations.
4
Municipal Corporation of Delhi v. Association of Victims of Uphaar Tragedy (2011)
19
4. WHETHER THE AFFECTED INDIVIDUALS ARE ENTITLED TO ADEQUATE
REMEDIES, INCLUDING COMPENSATION AND REHABILITATION, FOR THE
HARM CAUSED BY THE GAS LEAKS?
It is humbly submitted that the assertion that affected individuals are entitled to adequate
remedies, including compensation and rehabilitation, for the harm caused by the gas leaks
Affected individuals have a legitimate claim to adequate remedies for the harm caused by
the gas leaks, including compensation and rehabilitation. This is consistent with the
principle of environmental justice and the right to a clean and healthy environment
enshrined in Article 21 of the Indian Constitution.
Coromandel Garden International, as the entity responsible for the operation of the
chemical plant, bears liability for the harm caused by the gas leaks under the principle of
"polluter pays," as established in M.C. Mehta v. Union of India. The company is
obligated to compensate affected individuals for any loss or damage suffered as a result of
its activities.
The compensation awarded to affected individuals should be commensurate with the
extent of the harm suffered, including both economic and non-economic losses. This may
include compensation for medical expenses, loss of livelihood, pain and suffering, and
other consequential damages.
Additionally, affected individuals may require rehabilitation measures to recover from the
physical, psychological, and economic impacts of the gas leaks. This may involve access
to healthcare services, vocational training, and other forms of support to facilitate their
recovery and reintegration into society.
It is imperative that Coromandel Garden International fulfills its legal and moral
obligations to compensate and rehabilitate affected individuals promptly and adequately.
Failure to do so would not only violate the rights of the affected individuals but also
undermine principles of environmental justice and corporate responsibility.
20
M.C. Mehta v. Union of India (1987): In this case, the Supreme Court emphasized the
principle of "polluter pays," holding industries liable for environmental damage caused
by their activities. However, the court also recognized the need to balance environmental
protection with economic development and societal welfare.
Environment (Protection) Act, 1986:
encompassing the right to compensation for harm caused by environmental pollution.
In conclusion, the respondent asserts that affected individuals are entitled to adequate
remedies, including compensation and rehabilitation, for the harm caused by the gas
leaks. Coromandel Garden International bears liability for the harm under established
legal principles and should fulfill its obligations to compensate and rehabilitate affected
individuals in accordance with the law.
5
M.C. Mehta v. Union of India (1987)
21
PRAYER
WHEREFORE IN THE LIGHT OF THE ISSUES RAISED, ARGUMENTS ADVANCED AND

AUTHORITIES CITED, MAY THIS HON’BLE COURT BE PLEASED TO ADJUDGE, HOLD
AND DECLARE THAT:
1. Request for the Court to dismiss the allegations of breach of duty of care against
Coromandel Garden International regarding the gas leaks, emphasizing compliance
with relevant regulations and the unforeseeable nature of the incidents.
2. Appeal for the Court to recognize the continued operation of the chemical plant as
essential for economic development and societal welfare, balancing environmental
concerns with the right to livelihood.
3. Petition for the Court to reconsider the enforceability and sufficiency of the
magistrate's order to cease manufacturing activities, highlighting potential socio-
economic repercussions and advocating for proportionate measures to mitigate risks.
4. Petition for the Court to dismiss claims for compensation and rehabilitation against
Coromandel Garden International, highlighting legal and moral obligations, and
advocating for adherence to principles of environmental justice and corporate
responsibility.
AND/OR
PASS ANY OTHER ORDER THAT IT DEEMS FIT IN THE INTEREST OF JUSTICE,
EQUITY AND GOOD CONSCIENCE.
COUNSELS FOR THE RESPONDENTS
22

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DR.

AMBEDKAR GOVERNMENT LAW COLLEGE, PUDUCHERRY PRACTICAL TRAINING-IV

{WRIT Petition (Civil) No. of 2024}

MUKUL RASTOGI & ANR ................... PETITIONERS

UNION OF INDIA & ORS ........................... RESPONDENTS

[WRITTEN SUBMISSION ON BEHALF OF THE RESPODENT]

WRITTEN SUBMISSION BEFORE

Counsel for Respondent

2. AIR All India Reporter

6. Cr.P.C Code of Criminal Procedure

19. UOI Union of India

20. u/s Under section

21. Vol Volume

STATUTES, ACTS AND RULES

6. The Constitution of India, 1950

BOOKS AND COMMENTARIES

1. V.N. Shukla, Constitution of India, (12th Ed, 2016)

Article 21: Guarantees the right to life and personal liberty.

2. Acts and Sections:

1. WHETHER COROMANDEL GARDEN INTERNATIONAL BREACHED ITS DUTY OF CARE

2. WHETHER THE CONTINUED OPERATION OF THE CHEMICAL PLANT INFRINGES

4. WHETHER THE AFFECTED INDIVIDUALS ARE ENTITLED TO ADEQUATE REMEDIES,

1. WHETHER COROMANDEL GARDEN INTERNATIONAL BREACHED ITS DUTY

2. WHETHER THE CONTINUED OPERATION OF THE CHEMICAL PLANT

4. WHETHER THE AFFECTED INDIVIDUALS ARE ENTITLED TO

1. WHETHER COROMANDEL GARDEN INTERNATIONAL BREACHED ITS

WHEREFORE IN THE LIGHT OF THE ISSUES RAISED, ARGUMENTS ADVANCED AND

COUNSELS FOR THE RESPONDENTS

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