SPECIAL ARTICLE
Manufactured Silence
Political Economy and Management of the 1984 Bhopal Disaster
Adam B Lerner
Scholarship on the 1984 Bhopal gas tragedy tends to
treat the Indian judiciary as the site where political, social
and legal forces converged to betray survivors seeking
redress. But before this judicial failure, Prime Minister
Rajiv Gandhi had already politicised the disaster to
protect his economic modernisation programme.
Recognising the threat the Bhopal tragedy posed to the
ideology behind this agenda, Rajiv Gandhi and his
advisers pursued multiple strategies to suppress the gas
leaks resonance in larger political debates. This laid the
groundwork for the courts later miscarriage of justice
and helped shape the disasters subsequent place in
Indian economic history.
The author would like to extend his sincerest gratitude to Shailaja
Fennell, Satinath Sarangi, Rachna Dhingra, Devendra Panchal, Upendra
Baxi, Joya Chatterji, and Satbir Bedi for their helpful comments and
support in writing this article. Research for this article was supported
by St Johns College, University of Cambridge, via the Tutors Praeter
Fund and the Leathersellers Company Grant. Additional support was
provided by the Sambhavna Trust Library and Documentation Centre
in Bhopal.
Adam B Lerner (abl33@cam.ac.uk) is a PhD candidate at St Johns
College, University of Cambridge.
Economic & Political Weekly EPW JULY 29, 2017 vol liI no 30
S
cholarly work on the Bhopal disaster almost always
begins by calling it the worst industrial accident in
human history. This statement is terribly insufficient, as
it glosses over the significant neglect that led to the leak of the
methyl isocyanate (MIC) gas, and diminishes the extent to
which its roots were embedded in decades of Indian political
and economic history. Further, as Upendra Baxi notes, writing
about such an enormous catastrophe often devolves into a
form of epistemic violence when it fails to understand the mul-
tiple, highly individualised forms of trauma which emerge
from catastrophe or to acknowledge survivors significant
agency in shaping its aftermath (2010: 23).
What is undisputed is that, on the night of 23 December
1984, a cloud of MIC gas drifted from the multinational corpo-
ration Union Carbide Corporations (UCC) pesticide plant in
northern Bhopal southwards, into the adjacent bastis and
eventually across much of the Old City (Lapierre and Moro 2003:
part III). The number killed that night remains largely unknown;
a municipal waste truck driver recalled, to the International
Campaign for Justice in Bhopal, that, in the days following the
disaster, he and his colleagues either cremated or dumped
dozens of truckloads each with approximately hundred corpses
from around the city into the nearby Narmada river. Relying on
similar accounts and other data, the non-governmental organ-
isation (NGO) conservatively estimates a death toll, in the week
following the disaster, of 8,000. Amnesty International (2004),
likewise, has estimated that between 7,000 and 10,000 died in
the leaks immediate aftermath, with at least 15,000 more
perishing due to lingering effects and the citys continued con-
tamination. While both estimates are plausible, in many ways
the numbers game only serves to obfuscate a key facet of the
ongoing disaster. This poor documentation was in many ways
deliberate and has led not only to inadequate compensation
and rehabilitation, but also the disasters murky place in Indian
public consciousness.
Themistocles DSilva (2006) has demonstrated that UCCs
Indian subsidiary Union Carbide India Limited (UCIL) operated
very much under the auspices of Indias central government. In
1956, as UCC sought to expand its Indian operations to plastics
and other chemicals, the Government of India (GoI) insisted it
partially divest from its subsidiary and thus the company sold
40% of its equity to central government-run institutions. In
the 1960s, as the government launched Green Revolution
policies encouraging increased foodgrain production, it began
to rely on UCIL for its parent companys pesticide Sevin, an
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SPECIAL ARTICLE
alternative to the more commonly-used pesticide, DDT. The
government estimated that domestic demand for Sevin would
reach 5,900 million tonnes (mt) annually by 1974 with in-
creased agricultural production and thus, in December 1960,
granted UCIL a licence to import the pesticide from its parent
company in the United States (US). In 1966, due to the foreign
exchange issues inherent in such a massive import scheme, the
government granted UCIL a licence to manufacture 5,000 mt
of Sevin per year in India. UCIL began producing the pesticide
in 1967 at a plant in Trombay, Maharashtra, but moved pro-
duction to Bhopal in 1969, where it was granted numerous tax
breaks due to the regions classification as economically under-
developed.
As the GoIs Foreign Exchange Regulation Act (FERA) regime
tightened in the early 1970s, foreign companies began to leave
Indiatheir number dwindled from 540 in 1973 to 315 in 1980
with Indian subsidiaries declining from 188 to 118 (Martinus-
sen 1988: 158). The government, though, permitted UCC an ex-
ception to rules that barred any foreign company owning more
than 40% of its subsidiary, because it imported advanced tech-
nology and exported a sufficient portion of its production. In
197778, UCC did reduce its stake in UCIL to 50.9%, selling an
even larger stake to other government-controlled entities.
In the intervening years, the Indian government further ap-
proved UCILs plans to shift production to the more efficient
(but more dangerous) process that involved producing and
storing large quantities of MIC, which UCC employed at its
plant in West Virginia. But the plant in India did not incorpo-
rate all the automated safety features UCC employed at home,
opting instead for more labour-intensive safety measures,
which were susceptible to human error (DSilva 2006). Stor-
age of such large quantities of MIC in a populous urban area
alarmed many residentsone expert compared the stock to
an atomic bomb adjacent to the city (Lapierre and Moro
2003: 65). But UCIL retained its licence and sanction from both
the state and central governments, even after toxic fumes
killed a plant employee in 1981. And unable to find sufficient
demand in India for its high production capacity, UCIL began
to cut costs further around that time.
1 Political Economy and the Fallout
Though it would be an overstatement to suggest that the GoI
was somehow directly responsible for the leak, to date aca-
demic literature has largely neglected its partial ownership of
UCIL and the political, economic and moral implications of this
entanglement. Further, and perhaps more importantly, the lit-
erature almost entirely neglects the extent to which political
economy both shaped UCILs operations in India and its re-
sponse to the leak. This absence reflects the siloed and rela-
tively underdeveloped literature on the disasters politics. Thus
far, two notable streams of scholarship have dealt with the dis-
asters politics in varying capacities. First, sociological scholar-
ship has analysed local political activism among survivors in
the face of injustice (see, for example, Baxi 2000; Fortun 2001;
Mukherjee 2010; Zavestoski 2009). Second, legal scholarship
has reflected on how political considerations derailed the
58
Indian judiciary and led to the injustice of the 1989 settlement
(see, for example, Baxi 2010; Baxi and Indian Law Institute
1986; Cassels 1993; Galanter 1985, 1986). While both streams
are valuable, neither has dealt sufficiently with the political
economy of disaster management and how this shaped cir-
cumstances on the ground and in the courtroom.
The works that have commented on Bhopals relevance in
national politics (for example, Gonsalves 2010; Rajagopal 1987;
Rajan 2002; Rosencranz et al 1994) have tended to reflect far
more on its resonance in broader political economic debates,
rather than how political economic considerations actually
shaped its fallout. This addition would not only help integrate
the disaster into the periods economic history, but would also
provide a basis for connecting these literatures. Further, it
would help remedy a notable flaw in much of the literature on
post-Bhopal litigation: the lack of adequate explanation for
why the GoI ultimately settled for such a meagre sum. Baxi
(2016) has argued that in the year or two following the disas-
ter, the governments legal strategy first demonstrated a com-
mitment to Bhopal survivors, but that it later abandoned this
commitment and caved in to an unjust settlement. In this arti-
cle, though, I will demonstrate that any temporary signs of the
governments commitment to justice should be viewed as sus-
pect, as its handling of the disasters immediate fallout demon-
strated clearly that it was reluctant to pursue a legal strategy
that detracted from efforts to minimise the disasters political
resonance.
Upon rising to power, Rajiv Gandhi and his new generation
of Congress leaders aspired to pursue an ambitious modernisa-
tion programme, consisting of both economic liberalisation
and technocratic centralisation of power. But despite winning
a tremendous parliamentary majority, their mandate for major
reform remained fragile. The Bhopal disaster represented a
true political threat to those aims, as it served as a horrific
example of the risks inherent in their economic vision. Thus,
the government initially sought to contain the leaks scope in
the public imagination, funnelling potential proliferations into
the bureaucracy, where they could be suppressed, and under-
playing the disasters resonance publicly by treating it as
anomalous or accidental. By the time survivors had the space
to organise, and the legal battle over compensation began
after the passage of the 1985 Bhopal Gas Leak Disaster (Pro-
cessing of Claims) Act, 1985 (henceforth, Bhopal Act) the gov-
ernment had already secured ultimate control over the disas-
ters fallout. In these first four months, as the city of Bhopal
was still reeling, the GoI laid the groundwork for the multiple,
proliferating injustices that followed.
2 Rajiv Gandhis Modernisation Programme
Considering Wittgensteins maxim that modernity can be
shown but not easily be talked about, as well as the divergent
meanings ascribed to the term even in the limited context of
independent Indias developmental history, Rajiv Gandhis
invocation of tropes of modernity in reference to his political
and economic programmes warrants further investigation
(quote paraphrased in Gupta 2000: 85). Noting that Gandhis
JULY 29, 2017 vol liI no 30 EPW Economic & Political Weekly

tremendous initial popularity upon taking office in October
had some roots in the sympathy following his mothers
assassination, Harold Gould (1986: 633) adds that his tremen-
dous victory in the December 1984 elections was more than
just an emotional outburst. Rajiv Gandhi portrayed himself as
a no-nonsense chief executive, surrounded by quintessen-
tially modern, technocratic advisers. All were relatively new to
the system and thus, in theory, uncorrupted (hence support-
ers nickname for Rajiv Gandhi, Mr Clean). Whereas Nehru
had invoked the language of modernity, both in his state-led
industrialisation efforts and in his advocacy of a democratic
nation state based on compromise between Indias diverse
constituencies,1 Rajiv Gandhis initial rhetoric of modernity
embodied by his pledge to take India into the 21st century
revolved around the pursuit of efficiency in governance and
economic progress (Patel 1987). Though he inherited from his
mother an already highly-centralised state apparatus that had
begun liberalising reforms, Gandhi further centralised decision-
making during his initial months in office and declared his
intentions to go well beyond the limited liberalising measures
of the previous years (Gould 1986; Kohli 2000, 2006). Notably,
in November 1984, during his first major address after his
mothers assassination, Gandhi neglected to mention the rag-
ing anti-Sikh violence her assassination by Sikh bodyguards
had caused, but instead emphasised that his government
would underline innovation, transformation and modernisa-
tion to meet the demands of the 21st century (Times of India
News Service 1984a).
Significant debate persists over how successful Gandhi ulti-
mately was in achieving economic progress based on liberalis-
ing reforms,2 and Atul Kohli has demonstrated that political
circumstances forced Gandhi to abandon much of his most
ambitious proposals after only a year or so in office (Kohli
2000, 2006). But in December 1984, as MIC gas leaked out of
UCILs tanks in Bhopal and contaminated the city around it,
Gandhi was still riding a tremendous and multifaceted wave
of support for a modernisation programme that, in his and
many elite analysts opinion, extended to the dismantling of
significant controls on the economy (Patel 1987). The tension
between efforts to lessen government control over the econo-
my and allow more imports and foreign capital, while simulta-
neously centralising decision-making in what J Bradford De-
Long (2003) has called close to an elected dictatorship
should be abundantly clear. I G Patel (1987: 211) has described
this sort of tension as a typically Indian refusal to
choose between desirable thingsa desire to reap the eco-
nomic benefits of competition without necessarily subjecting
established interests (including governmental ones) to the loss
of power inherent in this dynamism. Thus, it should come as
no surprise that Gandhis economic liberalisation programme
dissolved into a pro-business strategy, promoting the power
of incumbent market heavyweights, rather than pro-market,
pro-competition, or even pro-growth (Kohli 2006).
The Bhopal disaster, which came during the most ambitious
early phase of Gandhis economic reform programme, laid
bare this tension precisely. An entrenched market player with
Economic & Political Weekly EPW JULY 29, 2017 vol liI no 30
SPECIAL ARTICLE
ties to local and national political figures and an advanced,
proprietary chemical technology vital to a past modernisation
effort, exhibited undisputable negligence that led to disaster.
The event demonstrated clearly the risks inherent in unac-
countable, large foreign businesses making decisions without
public actors forcing them to consider human costs. Veena Das
(2004: 142) has noted that, because of the disasters scope, the
public immediately interpreted it as a collective disaster that
directly involved the scientific, legal and administrative
structures of modern society and therefore implicated the
vision Gandhi was endeavouring to pursue. In this context, he
and his allies immediately understood that their job was not to
reduce public risk, which would almost certainly have the ef-
fect of deterring investment, but to acclimate the public to the
risks of private sector-led modernisation and centralised, elite-
led government.3 Das (2004: 137) has written that the Bhopal
disaster, as a challenge to this vision, required Gandhi and his
allies to construct a theodicy, comparable to that of a religion,
which protect[ed] the legitimacy of the state in the face of suf-
fering and evil. As I will demonstrate, this theodicywhich
defended not only the states legitimacy, but also Gandhis ten-
uous, multifaceted vision of modernisationproved vital in
preventing populist, anti-liberalisation outrage over the disas-
ter. Ultimately, the government constructed a narrative about
Bhopal as an anomalous accident, downplaying its extent in
the publics eyes for political gain while seizing control of its
ramifications for the bureaucracy.
3 Information Management and the General Elections
In comparing first-hand accounts of the desperation that followed
the 23 December gas leak and the GoIs cautious response, a
palpable dissonance emerges. T R Chouhan (Chouhan et al
1994: 40), a former MIC plant operator for UCIL in Bhopal,
recalls in a memoir waking up to white gas flooding his house
and the sounds of stampedes escaping the cloud. But even
hours after he had reached safety, Chouhan recalls a pervad-
ing confusion, with information on what had happened avail-
able only via rumour. [G]overnment officials and Union
Carbide were already behaving as though they were more inter-
ested in covering up the disaster than saving lives, he con-
cludes, pointing to the lack of information and the fact that local
officials did not evacuate many residents who could have es-
caped the clouds drift. In the days following the leak, he adds,
UCIL officials mendaciously insisted that MIC was like tear gas,
caused only temporary injury and could be treated with oxy-
gen, antacids and by flushing the eyes out with water, despite
the plant manuals clarity on its lethality. For days afterwards,
no government officials challenged them, despite MICs obvi-
ous result: human and animal corpses strewn across Bhopal.
A leading activist, quoted by Chouhan (in Chouhan et al
1994: 9, 3941), described a manufactured silence on the part
of UCIL and government officialsa statement which, in retro-
spect, doubles as a metaphor for the leaks macabre effects. Legal
scholar Jamie Cassels (1993: 11921) has similarly referred to
the GoIs bureaucratisation of justice in disaster manage-
mentan effort to funnel public outrage that could reflect
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poorly on larger government conduct and ideology into a gov-
ernment-controlled legal process intent on suppressing and
silencing it. This strategy, which became clear in the days fol-
lowing the leak, served two purposes: first, it allowed govern-
ment leaders to filter information before it reached the public,
and second, it immunised the GoI and its state subsidiary from
blame by making them intermediaries between victims and
justice. Ultimately, this approach allowed the government to
dismiss the disaster as anomalous and prevent its resonance in
economic policymaking.
Anees Chishti (1986), a freelance journalist reporting on the
disaster, kept a diary of the fallout that reveals not only the
extent of the government-constructed information firewall,
but also the central governments efforts to seize control of dis-
aster management from the Congress-led state government in
Madhya Pradesh. Immediately following the chaos, survivors
began directing their outrage at the states Congress party and
its Chief Minister, Arjun Singh, who reputedly had close ties
with UCIL.4 UCIL had donated large sums to the chief minis-
ters family foundation and many Bhopalis heard reports that
Singh had a suite reserved at the companys lavish guest house
for weekend sojourns (Rajagopal 1987: 139). Rajiv Gandhi,
who flew to Bhopal on 4 December for a 90-minute tour of the
affected areas, seemed acutely aware that negative percep-
tions of the state Congress party and its leader would reflect
poorly on the Congress party at the national level before that
months Lok Sabha elections. After the tour, at a press conference
at Bhopal airport, Gandhi refused to comment on any possible
state government liability, cited a fallacious death toll of a lit-
tle over five hundred, and falsely assured reporters that the
citys medical facilities had sufficient supplies to treat the enor-
mous number of victims. Before returning to campaigning,
Gandhi said his upcoming two-day campaign tour of Madhya
Pradesh would remain unchanged (Chishti 1986: 3132).
In the days following Rajiv Gandhis departure, Singh lied to
reporters about prior investigations of safety lapses, refused
to say whether he would shutter the plant and neglected to
mention that, in a ploy to garner electoral support, his govern-
ment had issued pattas to residents of adjacent bastis in dan-
gerous proximity of the gas. The central governments Minis-
ter of Chemicals and Fertilisers Vasant Sathe likewise falsely
told the media that the central government would not have
approved the plants construction had any settlements been
nearby at the timea risible statement considering the plant
was less than two kilometres from the citys historic centre.
After days of witnessing politicians baselessly assure citizens
that the air and their food supply was safe for them, Chishti
wrote that Arjun Singhs evasive answers were disgusting
and ultimately referred to press relations as a Theatre of the
Absurd (1986: 40, 42). At no point in Chishtis recounting of
the disasters immediate wake, however, does the GoIs owner-
ship stake in UCIL appear, an absence representative of other
journalistic accounts I have consulted.
While some of these government officials misinformation and
evasion can certainly be attributed to the chaos of the moment,
another substantial portion must certainly be attributed to a
60
managed campaign based on economic ideology. Considering
the upcoming national elections, approximately three weeks
away, in which Rajiv Gandhi hoped to secure a commanding
majority and, in his eyes, mandate for reform, these efforts
proved especially vital. Then the Finance Minister Pranab
Mukherjee, in his 2016 memoirs, wrote that in the days follow-
ing the disaster, he returned to Delhi for a meeting of the Cabi-
net Committee on Political Affairs, which included the Prime
Minister, Chief Minister Arjun Singh, and Vasant Sathe. In the
meeting, Sathe expressed his support for nationalising UCIL, a
strategy that would prevent UCIL from spreading further mis-
information and would likely prove popular with outraged
Bhopalis. But Mukherjee (2016: 8687) dissented, saying:
Union Carbide is a big multinational. Nationalising it would be com-
pared with the nationalisation of Coca-Cola and seen as a big mis-
take. Nationalisation will discourage future investments in India. As
finance minister, I have tried to woo foreign investors, NRIs, etc. This
will be a huge setback The Congress will win this election hands
down. Why vitiate the process? This will give a great handle to the
opposition.
As per this account, the Prime Minister was instantly per-
suaded and this viewpoint shaped the governments policy
moving forward.
4 Political Economic Considerations
Mukherjees statement is striking not solely because it repre-
sents a clear admission of allowing political economic consid-
erations to shape the governments response. His passive
voiceemployed in describing nationalisation as a big mis-
takeas well as the reference to the nationalisation of
Coca-Cola reveal a great deal about whom he saw as the chief
constituencies to which the government must appeal.5 Those
appraising nationalisations and deeming them mistakes
likely would not have been the general public. Under Indira
Gandhi, the nationalisation of Indias entire banking indus-
trya sector which had not created nearly the palpable suffer-
ing that UCILs plant didbecame a populist rallying-cry that
helped her secure a commanding majority in the 1971 general
elections (Torri 1975). Instead, implicit in Mukherjees quote is
that the foreign investors he needed to woo would be those
most likely to deem nationalisation of UCIL a big mistake.
The extent to which a few top government ministers made
such a sweeping decision without consulting the rest of their
party or any representatives of those affected sheds tremen-
dous insight into their modernisation programmea judi-
cious combination of centralisation of decision-making and
economic liberalisation.
And, sure enough, the governments Congress leadership
was able to suppress outrage over the disaster from even
remotely affecting the national elections. A S Abraham (1984)
wrote that month in the Times of India that, with the disaster,
opposition parties had missed a splendid opportunity to put
the ruling party on the dock and the Congress in its stronghold
of Madhya Pradesh over a national campaign based on plati-
tudes and sympathy for Indira Gandhis assassination, rather
than substantive issues. Despite the fact that national opposition
leaders such as Charan Singh and Chandra Shekhar demanded
JULY 29, 2017 vol liI no 30 EPW Economic & Political Weekly

the arrest of Congress leaders in Delhi and Bhopal, according
to political reporter Inder Malhotra (1984) and long-time Bhopal-
based activist Satinath Sarangi, Bhopalis and the larger public
remained unconvinced that Rajiv Gandhi or his government
were at fault. Though one survivors group did initiate a sym-
bolic boycott of local Lok Sabha elections, which had been
postponed until early 1985, this did not prevent the local Con-
gress Member of Parliament (MP) from being re-elected and
adding to Rajiv Gandhis already historic majority.6 The Congress
party ended up winning 404 of 514 available seatsa land-
slide that virtually guaranteed Rajiv Gandhi a full five years of
one-party rule (Manor 1985). By any stretch of imagination,
this Congress-led effort to prevent public outrage in Bhopals
immediate wake from affecting the national election or sparking
a debate over economic policy proved a tremendous success.
5 The People vs Warren Anderson
Less than a week after the disaster, on 7 December 1984, Warren
Anderson, the chief executive officer (CEO) of UCC, travelled
from the US to Bhopal. Upon landing, Madhya Pradesh state
police officers arrested him and two top company officials for
their role in the disaster. The three were detained at UCILs
guest house, but Anderson was mysteriously released six hours
later and flown back to Delhi in a government aircraft. After a
brief stop in the capital, he returned to the US before public
outrage over his release could mount, never to set foot on Indian
soil again. In the years before his death in 2014, multiple Indian
courts requested his extradition from the US and labelled him
a fugitive (Hanna et al 2005; Martin 2014; Times of India News
Service 1984b, 1984c).
Much of the academic literature analysing this saga has
debated the legal and ethical merits of holding a CEO crimi-
nally liable for a subsidiarys accident (see, for example,
Anderson 1993; Ladd 1991). Mass media coverage, by contrast,
has tended to harp on developments in Andersons case and
his absconding from justice as concrete examples of the linger-
ing injustice that continues to motivate survivors groups.
Though activists to this day burn effigies of Anderson on the
Bhopals streets, the Times of Indias editorial board expressed
another commonly-held opinion that the brief arrest was an
inexcusable bungle (Abraham 1984), since the state had no
indication of mens rea, or a guilty mind in the negligence
which led to the plants dangerous state. I have neither the
space nor expertise to opine on the merits of these debates
here. But regardless, in reconstructing the circumstances of
Andersons arrest and release, it becomes clear that the central
government in many ways interpreted the Madhya Pradesh
state governments actions through the lens of their economic
consequences, as any targeting of Anderson individually could
scare away foreign investors afraid of being scapegoated by
the Indian government in the event of an accident. Thus, the
central government seized control of Andersons case and
helped him leave India to prevent any spillover into the politi-
cal economic arena.
The best approximation possible of what happened follow-
ing Andersons landing in Bhopal comes from comparing the
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accounts of the various actors involved. Arjun Singh writes in
his memoir (Singh and Chopra 2012: 177) that hearing of
Andersons planned visit provoked a sense of outrage in him
and that he personally directed his state police to arrest the
CEO upon landing. Afterwards, Singh left Bhopal to join Rajiv
Gandhi on the campaign trail, where, he writes, he told Gan-
dhi about the arrest and that Rajiv Gandhi had no comment.
Later, during his campaign tour with the Prime Minister, Sin-
gh writes that he received a message from Brahma Swaroop,
Chief Secretary of Madhya Pradesh, who had received orders
from the then Home Minister P V Narasimha Rao to release
Anderson on bail and take him back to Delhi on a state plane.
Singh explicitly notes that he did not receive any direct orders
from Rajiv Gandhi, but he insinuates that Raos orders came
from the highest levels of government (Singh and Chopra
2012: 179). Previously top-secret Central Intelligence Agency
(CIA) documents obtained via request under the Freedom of
Information Act (FOIA) have corroborated this account of gov-
ernment leadershipincluding perhaps the Prime Minister
himselfordering Andersons release. American agents con-
tended that Singh scapegoated Anderson simply to score po-
litical points (CIA 1984). The opinion expressed by the Ameri-
cans is debatable, as the governments order for Andersons re-
lease before a court could rule on the cases merits was also
clearly political. Gandhi was planning to reset relations with
the US government at the time (Badhwar and Trehan 2013)
and to pursue an economic agenda whose success depended
on foreign investors and companies investing in India without
fear. Arresting Anderson, a powerful CEO of a large global
company, and holding him in an Indian jail would almost cer-
tainly have disrupted these plans.
Further, the GoIs efforts to work with Anderson and UCC
well before criminal investigations revealed his companys
complicity in the disaster reflects its desire to keep the case
from setting precedents that would scare away other foreign
investors. According to newspaper reports from the time, be-
fore returning home, Anderson discreetly met with Foreign
Secretary M K Rasgotra in Delhi to discuss preliminary com-
pensation and the need for a verification of the death toll
(State Seeks Legal View on Compensations 1984). Right to
information requests initiated by Bhopal survivors groups have
further indicated that Anderson was already negotiating a settle-
ment with the Ministry of Chemicals and Fertilisers, through his
companys Vice President Rolf Towe, by February of the following
year, before the Indian government had even seized control
of all litigation regarding the disaster via the Bhopal Act.7
Whether these criminal allegations were substantive or not, the
governments efforts to reach a settlement on behalf of survivors
with a fugitive from the Indian justice system, speaks volumes
of the governments centralised, pro-business plans.
6 Politics of the 1985 Bhopal Act
During the months after the national election, Rajiv Gandhi
rarely discussed the Bhopal disaster publicly or its possible
economic consequences, despite daily reports on it that peppered
Indian media. When Gandhi first did mention the Bhopal disaster
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in a speech in the Lok Sabha on 22 January 1985, the impor-
tance he gave it paled in comparison with his emphasis on the
future and pushing the nations industry to keep up with
industry in the rest of the world. He mentioned the tragedy
only in the limited context of environmental concerns, saying,
We have plans for cleaning up the air and the water in our country. We
have had the recent tragic accident in Bhopal where many people died
and many more were injured or are maimed we are looking at how
we can stop any factories polluting our rivers and our air.
He then moved to discussing a clean-up of the River Ganga,
an issue with arguably more communal resonance than envi-
ronmental (Gandhi 1987, Vol I: 15, 19, 20). This context, as
well as the description accident, clearly diminishes Bhopals
resonance as a metonym for broader issues that could threat-
en Gandhis centralisation of power or plans for economic
liberalisation.
But the clearest efforts to achieve these goals were found in
the March 1985 passage of the Bhopal Act, which deserves
analysis not just on its legal merits and practical outcomes, but
also as a reflection of government ideology. The act invoked
the legal doctrine of parens patriaeby which the sovereign
assumes legal responsibility for citizens unable to protect
themselvesto grant the government the exclusive right to
file all claims emerging from the Bhopal disaster. In doing so,
it nullified the numerous, and oftentimes conflicting suits al-
ready filed in India and the US by survivors and the Madhya
Pradesh government, and centralised power over the disasters
legal fallout in the hands of the Prime Minister and his inner
circle. Further, it included a compensation disbursement
scheme so that the GoI could manage any funds obtained via
its suit. Though, the law instructed government officials to
have due regard for any matters which victims could bring
up through their own, privately-purchased legal counsel, it did
not elaborate where survivors should direct their concerns or
how exactly the government would incorporate these victims
complaints. Further, the law did not specify a mechanism
through which they could air grievances with the rigid bu-
reaucratic system established by the associated disbursement
scheme (Bhopal Gas Leak Disaster [Processing of Claims]
Act, 1985 1986). This blatant disregard for the survivors legal
rights, as well as the rhetoric employed by Congress politicians
in advocating its passage, were clear indicators of the govern-
ments agenda in disaster management.
To be sure, the Bhopal Act did not appear out of thin air. The
impetus for the bill was the legal chaos created by the hordes
of American lawyers, who arrived in Bhopal in the days fol-
lowing the disaster and coerced clients into signing documents
they did not understand, to grant them power of attorney
(Wells 2014). By February 1985, numerous American attorneys
had filed multibillion dollar suits against UCC on the behalf of
survivors. An American federal judicial panel joined 145 of
these and assigned them to the Southern District of New York
(Muralidhar 2004). In India, rumours of these Americans
plans to keep up to 70% of any final compensation they won on
victims behalf sparked widespread outrage (Times of India
News Service 1984d). Arjun Singh responded by announcing
62
that his state government planned to waive all legal fees for
victims seeking compensation in Indian courts and establish
multiple legal aid and guidance camps to help victims pur-
sue their own claims in India (Galanter 1985; Gas Victims to
Get Legal Aid 1984). These multiple, overlapping legal ave-
nues created what Jamie Cassels (1993: 117) describes as a
reign of confusion, in which victims had no idea where to
turn for compensation. But still, despite the confusion, a con-
sensus emerged that whoever pursued the claims against UCC
should do so in the US, both because of Indias woefully under-
developed tort system and the US judicial systems history of
awarding large sums to victims of industrial disasters (Galanter
1985). Since most Bhopalis had little ability to pursue the case
in the US or clear the legal confusion themselves, there was a
widespread call for some sort of government intervention, as
Satinath Sarangi recalls. For these reasons, to date Upendra
Baxi (2010) still defends the acts legal merits, though he has
heavily criticised the way the GoI later utilised it.8
7 Bhopal Act as Betrayal
But even though many survivors supported the act in March
1985, Sarangi recognises that, in retrospect, this was a mis-
take. People thought they could exercise some control over
ones own government, unlike over foreign lawyers. But this
turned out to be untrue and he and other activists have come
to view the act as a betrayalan example of the government
unjustly seizing power for political reasons.9 Legal scholar
Aparna Viswanathan (1992) has likewise argued that the gov-
ernments invocation of parens patriae represents a significant
overreach. In English common law, Viswanathan adds, parens
patriae is a last resort, reserved for cases in which victims are
deemed unable to represent themselves (non sui juris) due to
mental incapacity or because they are minors without legal
guardians. Further, three additional criteria must be met for
parens patriae to be invoked: there must be no alternative to
the sovereigns representation; the sovereign must have a re-
sponsibility to protect the victim; and the sovereign may not
have a conflicting personal or proprietary interest in the mat-
ter. She notes that the GoI did not meet three of these four
conditions, as many victims were fully capable of seeking legal
redress, Indian law provided the alternative of a public interest
litigation, and the government did have a conflicting pro-
prietary interest, since in 1984 public companies owned 22%
of UCIL. Likewise, Jamie Cassels (1993: 11822) has written
that, even though the government had good reason to believe
that Bhopal victims did not have the resources to pursue their
case in US courts, American law barred parens patriae in
cases in which individuals were legally entitled to make
individual claims on their own behalf.10 The Indian gov-
ernments recourse to such a sweeping and unprecedented
legal measure to resolve issues that could have been dealt
with in a more restrained manner reflects their larger central-
ising ambitions.
And if the structure of the Bhopal Act leaves any doubt that
the government was partially motivated by concerns about its
modernisation programme, the rhetoric top Congress leaders
JULY 29, 2017 vol liI no 30 EPW Economic & Political Weekly

used to defend the bill should dispel it. Take, for example, the
Rajya Sabha debate on the issue on 18 March 1985. Early in the
session, before even addressing the bill, a member of the Com-
munist Party of India (CPI) probed the bodys Congress majo-
rity about the circumstances surrounding Andersons release,
but received no response from any Congress membera clear
indication of the sensitive politics of disaster management. But
as conversation shifted to the Bhopal Act, the ruling Congress
party justified its invocation of parens patriae using a dubious,
ideologically-driven logic. The Minister of Chemicals and Fer-
tilisers Veerendra Patil, representing the governments posi-
tion, argued that because most of the victims of the disaster
are and were poor people, it becomes the duty of both the state
and central governments to see that those who have suffered
in this disaster are properly rehabilitated and the families of
those who have died are properly compensated (GoI 1985).
Later, he referred to foreign lawyers that signed up survivors
as clients, even though they could not read, and they might
not be knowing what [the documents they signed] contained
as an indication of the victims legal incompetence. This argu-
ment, of course, was completely spurious; if extended to its
logical conclusion, it would undermine the countrys entire ju-
dicial system, as a vast number of Indians were poor and illit-
erate and a majority had no true legal education. Further, as
an opposition representative pointed out, the Indian govern-
ment could not possibly be expected to file an adequate suit on
survivors behalf that month as it did not yet have any reliable
scientific data on the number of gas-affected and the extent of
the damage (PTI 1985a). Despite these complaints, the bill was
passed by the Congress majority, and the government took the
case to the US (PTI 1985b).
While the government hoped to portray the Bhopal Act as
the only viable option, this was simply not the case. Philip
Knightly, for instance, argued that despite the sleazy tactics by
American lawyers, survivors ought to retain their services as
they offered the best means of securing a multibillion dollar
sum. An explanation of the true roots of the disaster will not
come from any government-inspired inquiry in India or any
locally lodged lawsuit, Knightly wrote, likely referring to
Indian courts limited ability to collect necessary materials.
[Justice] will come only from the class action launched in the
US by the much-maligned American compensation lawyers
(Knightly 1985). Likewise, Marc Galanter, who has praised the
Bhopal Act for linking Indias weak judicial system with the
much stronger one in the US, notes the existence of alterna-
tives.
One might imagine other possibilities for providing linkage to a strong
remedy system, including multinational law firms, networks of law-
yers along the lines of corresponding banks, international placement
and matchmaking services, or such devices as trade union insistence
on favourable choice of law provision. (Galanter 1986: 30304)
The complaints about the Bhopal Acts sweeping mandate,
along with the multiple alternatives to its passage (each with
varying merits or feasibility), further an impression that the
GoI advocated the law partially to further its control over
Bhopal litigation. The laws outcome proved extremely
Economic & Political Weekly EPW JULY 29, 2017 vol liI no 30
SPECIAL ARTICLE
advantageous for the government leadership, especially consid-
ering its anxiety over the disasters legacy challenging the
modernisation agenda. First, by representing all of Bhopals
victims, the government would not only be able to arouse sym-
pathy from survivors by portraying itself as their champion,
but also would be able to shape the plaint to keep its ramifica-
tions from threatening its modernisation agenda. Second, the
law prevented any survivors from pursuing suits against the
central government or the Congress-run state government,
thereby preventing politically detrimental lawsuits that would
expose the state partys entanglement with UCIL or the central
governments role in facilitating the plants creation. Even
though it clearly usurped the democratic rights of Indian citi-
zens with specious justification, the government deemed it a
worthy price to pay to suppress numerous opportunities for
populist-infused revolt to challenge its agenda.
8 Conclusions
The GoIs actions between December 1984 and March 1985 did
not represent isolated bungles or even a temporary policy
change. Even as politics forced Rajiv Gandhi and his allies to
scale back their ambitious economic modernisation agenda
(Kohli 2006), the governments approach to the management
of the Bhopal disaster continued. US courts ordered the GoI to
file its suit against UCC in Indian courts and, as the case pro-
gressed, survivors continued to await adequate compensation
and rehabilitation. In 1989, much to the chagrin of survivors
groups, the government agreed to settlewhat had originally
been filed as a multibillion dollar plaintfor a $470 million
suit, a paltry sum considering legal precedent and the hun-
dreds of thousands that were affected. And though, in the
wake of the settlement, survivors groups launched valiant
protests and filed multiple suits challenging the validity of the
1985 Bhopal Act and the litigation process it spawned, the Su-
preme Court upheld the settlement in 1991.
This settlement constituted a major violation of due process
and a miscarriage of justice for numerous reasons, only a few
of which I have space to enumerate. First, the government un-
justly barred victims from participating in any aspect of settle-
ment negotiations. This exclusion, which has since been upheld
multiple times in American and Indian courts, was facilitated
by the 1985 Bhopal Acts vague, non-binding language on vic-
tims incorporation in the legal process. Second, the Supreme
Court grossly underestimated the total number of victims in
its calculations, including only 2,000 fatalities and 2,000 vic-
tims with severe injuries. Both figures contradicted existing
scientific reports as well as basic logic for those involved (Baxi
2010: 2425, 34). Third, in 1989, very little was known about
the long-term effects of MIC poisoning and the expenses it
would entail. Without this information, setting a fair, fixed
compensation package was impossible. Finally, the court did
not secure a true admission of fault from UCC or UCIL, thus en-
tirely refusing to address the larger issue of the companys ex-
ploitation of a developing nations lax regulatory power (Plan-
ning for a National Commission on Bhopal Gas Disaster 1991;
Union Carbide Corporation v Union of India 1989).
63
SPECIAL ARTICLE

The politics which infused the disaster response began in
December 1984 and continued thereafter, setting the stage for
a politicised courtroom battle and its unjust outcome. Empha-
sising the political economic motivations behind the govern-
ments disaster management is important not solely because it
illuminates the Bhopal disasters place in Indias political eco-
nomic history, but also because it opens out new avenues for
scholarship to explore political economys influence on the
legal saga and to connect Upendra Baxis tremendous insight
on how proceedings in Indian courts led to such a substantial
miscarriage of justice with a larger understanding of the
periods politics. This is a vital endeavour. For too long, Bho-
pal has been virtually forgotten in the public imagination
and left out of debates about economic development. The
Bhopal disaster was deeply embedded in Indias economic
history and its survivors deserve their story to be incorporat-
ed in relevant policy debates so that such a travesty never
occurs again.

Notes
1 For more on this, see, for example, Bilgrami
(1998); Khilnani (1997).
2 J Bradford DeLong (2003) has suggested that
Rajiv Gandhi was able to accelerate economic
growth both by passing modest reforms, but,
perhaps most importantly, by ushering in a sig-
nificant intellectual transition that fundamen-
tally altered elite attitudes towards economic
liberalisation and created economic optimism.
Panagariya (2004) has criticised DeLongs work
for overstating what amounted to unsustaina-
ble growth based on fiscal excess.
3 On this point I am grateful to Upendra Baxi,
with whom I corresponded throughout 2016 to
discuss several issues relating to the Bhopal
disaster.
4 Satinath Sarangi, personal communication,
30 March 2016.
5 It is worth noting that this argument is not only
biased, but deceptive. The government never
actually nationalised Coca-Cola. Instead, the
company withdrew from India following gov-
ernment requests that it divulge its secret for-
mula (Gopinath and Prasad 2012).
6 Satinath Sarangi, op cit.
7 Correspondence from B B Singh, Secretary,
Ministry of Chemicals and Fertilisers, to K Par-
asaran (then attorney general of India), Romesh
Bhandari (foreign secretary), B S Sekhon (law
secretary), and S Varadarajan (secretary and
director general, CSIR), dated 28 February
1985. Archived at the Sambhavna Trust Library
and Documentation Centre, Bhopal.
8 Upendra Baxi, serving as an advocate on be-
half of survivors groups, actually played a role
in crafting the legislation and the govern-
ments initial legal strategy. This does not neces-
sarily impugn his thoughts on its validity, but is
worth noting when considering his opinion.
9 Satinath Sarangi, op cit.
10 American courts never ruled on the validity of
the 1985 Acts invocation of parens patriae,
since the case was sent back to India on the
grounds of forum nons conveniens (inconvenient
forum).
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Features
Presents All-India
and state-wise
annual data from
1980 onwards.
Structured in six
major sections :
Demography
Health Status
Infrastructure
Human Resources
Health Education
Health Finance
65