Strict Liability for Environmental Pollution by Manufacturing Companies in Anambra State

Industrial pollution by manufacturing companies in Onitsha and Nnewi in Anambra State, South East Nigeria, has caused significant harm to communities, agricultural land, and water resources, raising important questions about the application of strict liability principles in Nigerian environmental law. This study examines the application of the strict liability rule in Rylands v Fletcher and its development in Nigerian case law to industrial pollution scenarios in Anambra State, focusing on cases decided between 2018 and 2024. Using a doctrinal and socio-legal methodology, the research analyses court decisions, National Environmental Standards and Regulations Enforcement Agency enforcement actions, and records from the Anambra State Ministry of Environment, supplemented by interviews with 50 affected community members and 15 environmental lawyers. Findings reveal that while the strict liability rule is formally recognised in Nigerian law, its practical application is significantly hampered by judicial reluctance to impose liability without proof of negligence, the difficulty of establishing causation for diffuse pollution, and the limited financial resources of affected plaintiffs. The study evaluates whether the introduction of a dedicated environmental liability statute could better serve pollution victims. Recommendations include strict liability codification for hazardous industrial activities, mandatory environmental insurance, and expanded standing rules for community plaintiffs. Keywords: strict liability, environmental pollution, Anambra State, manufacturing, Rylands v Fletcher