In M.C. Mehta Vs. Union of India, AIR 1987 SC1086 (Sri Ram Fertilizers case) the court held that

In escape of toxic gas, the enterprise is strictly and absolutely liable to compensate all those who are affected by the accident and such liability is not subject to any of the exceptions which operate vis-a-vis the tortious principle of strict liability.

In escape of a dangerous animal the owner is strictly and absolutely liable to compensate all those who are affected by the accident and such liability is not subject to any of the exceptions which operate vis-a-vis the tortious principle of strict liability.

In escape of toxic gas, the enterprise is strictly liable to compensate all those who are affected by the accident and such liability is subject to any of the exceptions which operate vis-a-vis the tortious principle of strict liability

A company or a corporation is not a state and hence not liable for leak of toxic gas affecting the health of the people