Hon'ble Supreme Court of India observed, “In M C Mehta case, no compensation was awarded as this Court could not reach the conclusion that Shriram company came within the meaning of ‘State’ in Article 12 so as to be liable to the discipline of Article 21 and to be subjected to a proceeding under Article 32 of the Constitution….
The Polluter Pays principle demands that the financial costs of preventing or remedying damage caused by pollution should lie with the undertakings which cause the pollution, or produce the goods which cause the pollution….”
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