Notes & Sources



1. Indian Ministry of Law note to Prime Minister’s Office, Feb 2, 2008
2. Lord Coe appearance before House of Commons Culture Media & Sport Committee, Nov 15 2011
3. Supreme Court of India, Union Carbide Corporation and others vs Union of India and others, Oct 3, 1991
4. Andrew Liveris interview with Bloomberg, Feb 28, 2012

All newspaper cuttings and original photographs from Sambhavna Document Library Collection
p14 True Death Toll Testimony of municipal worker Mohammed Karim as given to BMA Trustee Tim Edwards, April 2001
p 16 Justice in Alligator Boots, by Trevor Fishlock, first published in The Times, London, Dec 11, 1984

1. Warren’s Anderson’s possible escape by rowing boat from the account of journalist Anjali Deshpande, also quoted in her 2012 novel Impeachment, p.97. ‘They had waited and waited, typewriters perched on the low boundary wall of the building, notebooks in hand…trying unsuccessfully to hound the cars that brought in US embassy officials, till agencies flashed the news that he had left Bhopal. Even the fact that he had been smuggled out of the unused rusty back gate, taken off its hinges after the padlock hung on the thick iron chain refused to cooperate with officials desperate to let the man in their custody escape, rowed across the lake in a boat and taken to the airport to be flown to Delhi…’

22-27 LIE & LET DIE
All news cuttings and contemporary photographs from Sambhavna Trust Document Library
1. Phosgene Unit & Methyl Isocyanate Unit Safety Considerations Report ucil w.o. 930-4533/4534,
Engineering Dept, Chemicals & Plastics, Union Carbide Corporation Technical Center, South Charleston, West Virginia, USA, ucc e.o 938-6795, by J. F. Dodd, G.E. Rutson et al, Dec 16, 1974
2. Jackson Browning, quoted in Clouds of Injustice: Bhopal Disaster 20 Years On , p.50, Amnesty
International, AI index-ASA 20/015/2004
3. Telex of UCC Medical Director Dr Bipin Avashia, cited by Dr N.R. Bhandari, Medical Superintendant, Hamidia Hospital, Bhopal, in The Cloud Over Bhopal, Anil Agarwal, New Scientist, Nov 28 1985
4. Statements of Dr. Hans Weill and Dr. G. Peter Halberg, Encouraging Prognosis Is Seen For Gas Victims, William K. Stevens, New York Times, Dec 15 1984
5. Bhopal Collector Moti Singh’s visit to the UCIL plant described by Additional District Magistrate H.L. Prajapati in The Gas Tragedy: An Eye Witness, pp25-27 and p. 31, Mittal Publications, New Delhi, 2003
6. UCIL Chief Medical Officer Dr L.S. Loya quoted in Paying For Bhopal, Russell Mokhiber, Multinational Monitor, Vol VI, No 10, July 31 1985
7. International Confederation of Free Trade Unions, The Report of the ICFTU-ICEF Mission to Study the Causes and Effects of the Methyl Isocyanate Gas Leak at Union Carbide Pesticide Plant in Bhopal, India on
December 2-3, 1984. May 1985
8. ‘Do to do and La dee da’, Dr L.S.Loya quoted in The Culture of Make Believe, p. 286, Derrick Jensen, Chelsea Green Publishing, Jan 1, 1990
9. ‘The State Health Director finally received solid information on the chemical (MIC) from the World Health Organisation several days after the accident’, Report of the ICFTU, p.11, May 1985
10. Bhopal Chief Pathologist Dr Heeresh Chandra, Financial Times, Dec 8 1984
11. Dr Ingrid Eckerman, The Bhopal Saga p.53-55, Universities Press (India) Pvt Ltd/Orient Longman, Hyderabad, India, Dec 2004
12. Dr John Bucher, US National Institute of Environmental Health Science, quoted in Health & Safety at Work, p.7, Aug 1986
13. Dr N.R. Bhandari, 25 Years of Bhopal Gas Tragedy: Inside Story and Untold Truths, Lalwani Publications, Bhopal, 2010
14. Quoted in Tara Jones, Corporate Killing, p.26, Free Association Books, London, 1998
15. Chemical and Engineering News, Feb 11, 1985, p. 37
16. ‘Minutes of the Chemical Manufactuers’ Assoc. Executive Committee Meeting,’ January 28, 1985
17. Health Effects of the Toxic Gas Leak from Union Carbide Methyl Isocyanate Plant in Bhopal: Technical Report on Pathology and Toxicology 1984-1992, Bhopal Gas Disaster Research Centre, Medico Legal Institute, Mahatma Gandhi Medical College, Bhopal & Institute of Pathology (Indian Councul of Medical Research) New Delhi, 2010
18. Telex from Union Carbide USA, Dec 5, 1984, reproduced in The Bhopal Tragedy, One Year After, an Appen Report, Shabat Alam, Malaysia, 1985 p.110
19. Environmental Pollution and Bhopal Killings by Bhojendra Nath Banerjee, p. 121, South Asia Books, 1987
20. Minutes of a Meeting Between Medical College Doctors and Dr Max Daunderer on 8 December 1984 reproduced in Appen p.111
21. ‘The toxicological studies carried out so far… have clearly shown that, at least in the survivors, there is evidence of chronic cyanide poisoning operating as a result of either inhalation of hydrocyanic acid or more probably subsequent generation of cyanide radical from the cyanogen pool in gas-affected victims. The changes in urinary thiocyanate and in blood gas before and after thiosulphate treatment substantiated the above findings.’ Observations of the ICMR, February 1985, quoted in Tara Jones, Corporate Killing, p.114
22. The Cloud Over Bhopal, Anil Agarwal, New Scientist, Nov 28 198524. New Scientist, p. 41
23, 24. Agarwal, Anil, and Sunita Narain. The State of India’s Environment 1984-85: The Second
Citizens’ Report. New Delhi: Centre for Science and Environment, 1985, p.219. ‘Union Carbide’s own pronouncements from the US added to the chaos. Carbide’s medical director in the US, Bipin Avashia, cabled the authorities in Bhopal to administer sodium thiosulphate to the victims “if cyanide poisoning is suspected”. But at his press conference in Bhopal 10 days after the disaster, Avashia got into a slanging match with Bhopal’s doctors crying out: “It is not phosgene, it is not phosgene, it is not phosgene”. He argued that there could be no cyanide poisoning and sodium thiosulphate was no antidote to MIC poisoning. Union Carbide even issued a statement: “MIC is not a cyanide. In no way should it be confused as such. MIC naturally degrades in the environment by reacting readily with water to become harmless substances while cyanides do not react with water.” But when quizzed how he could have suggested administration of sodium thiosulphate in his first cable, he simply said that he could not be expected to know what sort of gas the Bhopal plant stocked. However, the telexed prescription had clearly referred to ‘treatment of MIC pulmonary complications.’
25. Asbestos Information Association, minutes of meeting held on Dec 9 1976 at the Mayflower Hotel, Washington DC
26. Statements of Dr. Hans Weill and Dr. G. Peter Halberg, Encouraging Prognosis Is Seen For Gas Victims, William K. Stevens, New York Times, Dec 15 1984
27. Quoted in Asbestos: Medical and Legal Aspects, Barry I. Castleman, p.570, Aspen Publishers, 2005
28. New Yorker June 10, 1985, Annals of Law: The Asbestos Industry on Trial pp49-101, especially p.89
29. Agarwal, Anil, and Sunita Narain. The State of India’s Environment 1984-85: The Second Citizens’ Report. New Delhi: Centre for Science and Environment, 1985. ‘Pointing out that if UCC had been honest about cyanide poisoning, hundreds of lives may have been saved, an angry article in Business India concluded: ‘The impression is inescapable that there were concerted efforts by the senior-most members of Bhopal’s medical establishment to suppress information on the nature of this mass poisoning.’
Said Tania Midha in another report in The Telegraph, ‘Interestingly, most documents produced by Dr Mishra in refuting the validity of Dr Heeresh Chandra’s claims, are studies by Bryan Ballantyne, the expert sponsored by Union Carbide to visit Bhopal.’
30. Bhopal: Disaster Seeking An Antidote, Ian Jack, Sunday Times, Dec 1, 1985
31. Unfolding the Betrayal of Bhopal Gas Tragedy, pp.216-220 Moti Singh, B.R. Publishing Corporation, 2008
32. Copy of confidential letter by B.B.L. Mathur, Dean of Gandhi Medical College, Bhopal, reproduced in Appen, p.121.
33. ICMR interim results May 1985. ‘ICMR instructed the state government to use sodium thiosulphate because patients given the injection reported remarkable improvement, and tests showed 8-10 times increased quantities of thiocyanate in the urine, which indicated that the body was getting rid of the poison. In early May, ICMR announced that biochemical tests had confirmed that MIC had affected the haemoglobin in the blood through a ‘carbamylation’ process, reducing its ability to carry carbon dioxide away from the tissues. Thus, even though the blood was rich in oxygen, tissues were starving for it.’
34. Agarwal, Anil, and Sunita Narain. The State of India’s Environment 1984-85: The Second Citizens’ Report. New Delhi: Centre for Science and Environment, 1985. p.220 ‘Heeresh Chandra argued that death was due to or similar to cyanide poisoning and pushed for the immediate use of sodium thiosulphate — the known antidote — as patients were still dying. A large number of deaths occurred within the first 48-72 hours. But for inexplicable reasons, he only met with ridicule from his own colleagues who demanded more
evidence. Said N P Mishra: “You are a doctor of the dead, so do not interfere with the living.”’

All newspaper cuttings from Sambhavna Document Library Collection Photo pp. 28-9 by Micha Patault, of Bhopal coroner Dr Satpathy with aborted foetuses at Hamidia Hospital, Bhopal
1. Dr Ingrid Eckerman, quoted in Graveyard Bullies, Outlook India, Oct 19, 2009
2. Article based on The Babies of Bhopal by Ritu Sarin, Sunday Magazine, July 1985.
3. Dr Daya Varma’s Sept 1985 study published as Epidemiological &  Experimental Studies on the Effects of Methyl Isocyanate on the Course of Pregnancy, Environmental Health Perspectives, Vol LXXII, pp153-157, September 1985
4. Pregnancy Outcome in Women Exposed to Toxic Gas at Bhopal, Dr N.R. Bhandari et al, Indian Journal of Medical Research, Section B, 1990, Vol XCII, No 2, pp.28-33
5. Article by researcher N. Ganesh in The Lancet Volume CCCLX, Number 933614, Sept 2002. See also Frequency of Acrocentric Associations in Bhopal Gas Tragedy Survivors, International Journal of Cell and Molecular Biology, I (2010) pp.26-30
6. Health Effects of the Toxic Gas Leak from Union Carbide Methyl Isocyanate Plant in Bhopal: Technical Report on Pathology and Toxicology 1984-1992, Bhopal Gas Disaster Research Centre, Medico Legal Institute, Mahatma Gandhi Medical College, Bhopal & Institute of Pathology (Indian Councul of Medical Research) New Delhi, 2010

Newspaper cutting from Sambhavna Document Library Collection, Judge Rejects Sabotage Theory, Jan 4 1986 (the judge referred to is Keenan in New York)
p32 – Union Carbide ad widely published in National Geographic and other US magazines c.1962
1,. Wake Up People of Bhopal, You Are On The Edge of a Volcano, Rajkumar Keswani, Jansatta, Sept 1982
2. Based on occupational health and safety exposure threshold limits
3. International Confederation of Free Trade Unions, The Report of the ICFTU-ICEF Mission to Study the Causes and Effects of the Methyl Isocyanate Gas Leak at the Union Carbide Pesticide Plant in Bhopal, India on December 2-3, 1984. May 1985. The report, based on interviews with UCIL workers, says 82 tons were stored in tanks E-610 and E-611, but ‘some of the MIC in the second storage tank, 611, was converted
to carbaryl after November 24th.’
4. Affidavit of Eduard Muñoz in Union Carbide Corp Gas Plant Disaster at Bhopal, India in Dec 1984, Judicial Panel on Multi-District Litigation, docket no. 626, Jan 28, 1985
5. Council for Scientific & Industrial Research, Report on Scientific Studies on the Factors Related to Bhopal Toxic Gas Leakage, Dr S. Varadarajan et al, Dec 1985
6. Union Carbide India Limited Methyl-Isocyanate Based Agricultural Chemicals Project, Review of Capital Budget Proposal: 1973-8, Feb 1977
7. Union Carbide India Limited Methyl-Isocyanate Based Agricultural Chemical Project, Capital Budget Proposal, Dec 2, 1973
8. Confidential memo of Union Carbide Eastern Ltd (Hong Kong) dated Feb 24, 1984
9. Business confidential Operational Safety Survey CO/MIC/Sevin Units, Union Carbide India Limited Bhopal Plant, C.S. Tyson et al, conducted May 3, 1982, circulated July 23, 1982
10, 11, 12. Multiple sources including Bhopal: The Inside Story – Carbide Workers Speak Out on the World’s Worst Industrial Disaster, T.R. Chouhan, Apex Press May 1995; International Confederation of Free Trade Unions, The Report of the ICFTU-ICEF Mission to Study the Causes and Effects of the Methyl Isocyanate Gas Leak at the Union Carbide Pesticide Plant in Bhopal, India on December 2-3, 1984. May 1985, articles by Rajkumar Keswani in Jansatta, Indian Express; Clouds of Injustice: Bhopal Disaster 20 Years On , p.50, Amnesty International, ai index- asa 20/015/2004
13. Confidential memos and telexes of the Worldwide Agricultural Products Team, comprising executives from Union Carbide Eastern, Union Carbide Agricultural Products and Union Carbide India Limited – documents obtained via discovery in 1985-6 and 2010-11
14. Confidential memo from R. Natarajan, Vice President Union Carbide Eastern, UCE Hong Kong to J.B. Law, Chairman, UCE Danbury, Connecticut, Subject: A Review of UC India Ltd’s Ag Products Business, Feb 24, 1984
15. Sept 11, 1984, Union Carbide Had Been Told of Leak Danger, Philip Shabecoff, New York Times, Jan 24, 1985.
16. p.37, State of Madhya Pradesh vs Warren Anderson and others, criminal case no. 8460/1996, decided June 7, 2010 by Judge Mohan P. Tiwari
17.  Memorandum of Law in Support of Union Carbide Corporation’s Motion to Dismiss These Actions on Grounds of Forum Non Conveniens, 31 July, 1985, in In Re Union Carbide Corporation Gas Plant Disaster at Bhopal, India in December, 1984, 634 F Supp 842 (SNDY 1986)
18. Union Carbide: Disaster at Bhopal, Jackson B. Browning, Vice President, Health Safety and
Environmental Programs, Union Carbide Corporation
19. Jan 7, 1987, Government of India response to Union Carbide Corporation sabotage claim.

Testimonies from We Will Never Forget 1986-1987, Bhopal Group for Information & Action, Dec 1987

1. Warren Anderson, Letter to Union Carbide stockholders, Feb 27, 1985
2. Melvin Belli, quoted in Enter justice, in alligator boots and a polka-dot tie, The Times, December 11, 1984
3. Minutes of meeting between Carbide executive Rolf H. Towe and Union Carbide India Managing Director Gokhale, at Ministry of Chemicals & Fertilisers, New Delhi, Feb 28, 1985, obtained via a RTI (Right to Information ) request
4,5. March 4, 1985. Carbide draft proposal to the Government of India for settling the Bhopal case.
6. The Bhopal Gas Disaster (Processing of Claims) Act, 1985. 29 March 1985. ‘An Act to confer certain powers on the Central Government to secure that claims arising out of, or connected with, the Bhopal gas leak disaster are dealt with speedily, effectively, equitably and to the best advantage of the claimants and for matters incidental thereto.’
7. Attorney: Conflict Issue is Tactic to Delay Bhopal Litigation, Karren Mills, Associated Press, Apr 11 1985
8. Bud Holman, UCC’s legal counsel with the firm Kelly, Drye and Warren, Transcript of January 3, 1986 hearing before Judge Keenan, p. 22; & Carbide Plays Hardball in Court, Steven Adler, American Lawyer, Nov 1985, p.62
9. Amnesty International, Clouds of Injustice, p.61
10. Russell Mokhiber, Paying for Bhopal, Multinational Monitor, July 31, 1985 – Volume 6 – Number 10
11. John David Rose, Rescuing Capitalism From Corporatism: Greed And The American Corporate Culture, p.40. ‘Of the settlement, $200 million was covered by Union Carbide’s insurance…’
12. 50,000 rupees spread over more than 27 years, the notional daily value continues to diminish as time passes, the actual money has long since been used up
13. In Re Union Carbide Corporation Gas Plant Disaster at Bhopal, India in December, 1984, 634 F Supp 842 (SNDY 1986)
14. ‘Union Carbide will not appear because, as a United States corporation, it is not subject to India’s jurisdiction’, said Robert Berzok, Carbide’s director of communications’ from India Acts in Carbide Case Reuters, May 17, 1988
14b. Poison Gas, Up Two Bucks, Editorial, The Nation, March 6, 1989
15. A full discussion of the compensation process is available in Amnesty International, Clouds of
Injustice, pp. 63-71
16. Union Carbide Corporation v. Union of India (1991) 4 SCC 584.

Radha Kumar. Adapted from article of the same name first published in the Hindu, Mar 26 1990

Letter dictated by Sajida Bano to Suketu Mehta, published in Bhopal Lives, The Village Voice, 1991

Based on interview with Harishankar Magician by Suketu Mehta, published in Bhopal Lives, The
Village Voice, 1991

Story compiled from interviews with Rashida Bee and other women, by several interviewers

Article sourced from Compensation Disbursement: Problems and Possibilities, a report of a survey
conducted in three gas affected bastis in Bhopal – Bhopal Group for Information & Action, Jan 1992

Personal account by Satinath Sarangi of a 1989 visit to the US with survivor Sunil Kumar and a 1991 visit with former UCIL plant operator T.R. Chouhan

1. Bhopal: 25 years of poison, Indra Sinha, The Guardian, Dec 3, 2009
2. ‘Medicine for the fields’ cited in Five Past Midnight in Bhopal, Dominique Lapierre and Javier Moro, Scribner 2003
3. Testimony of Bhavesh, given at Sambhavna Clinic, Bhopal
4. Confidential Union Carbide India memo, obtained via discovery in US court proceedings, exact date not known but after mid-May 1990.
5. Assessment of pollution damage due to Solar Evaporation Ponds at UCIL, September 1989, cited in letter, David Langseth, Arthur D Little, to Norman Gaines, UCC, November 10, 1989, UCC 01823
6. National Toxics Campaign Fund, 1990. Union Carbide in Bhopal, India: the lingering legacy. Boston:
Citizen’s Environmental Laboratory
7. Subimal Bose letter to Babu Lal Gaur , Minister for Gas Relief and Rehabilitation, Madhya Pradesh,
Untitled, May 16th, 1990.
8. Re. Response to allegations of environmental contamination around the Bhopal Plant site, Business Confidential, UCC Health Safety and Environmental Affairs Dept, to CC Smith Jr, May 22nd 1990. UCC 02049-50
9. Chouhan, T.R. (2000) Affidavit of Tota Ram Chouhan, Index no. 99 Civ. 11329 (JFK), United States District Court Southern District of New York, 3rd July 2000, 6pp
10. Letter, Norm Gaines, UCC Health, Safety and Environmental Affairs, Site Rehabilitation Project – Meeting 30 October in Danbury, to M.D. Buckingham et al, Nov 9, 1989. UCC 01810-01818
11. Letter, Subimal Bose, Director UCIL, Internal investigation at Bhopal Plant site, to Norm Gaines, UCC, March 30, 1992. UCC 03550
12. Talk with Rehana’s parents, Chingari Trust 2006
13. US Engineers at South Charleston, West Virginia misgivings about Solar Evaporation Ponds. Record Memorandum, GR Hattiangadi, Sevin Project, UCIL, Disposal of By-product HCl, May 7, 1972. UCC 04516
14. ibid.
15. T.S. Shah, Humphreys and Glasgow Consultants Private Limited, Bombay, Minutes of meeting No. 172 held between UCIL, M/s. K Datye and H&GC on 19-1-77 in H &GC Offices. 20th January 1977. UCC 04922-24
16. Telex 1. William Correa, Bombay, to H. Ayers, UCE Hong Kong, 03/25/82. UCC 0173 / Telex 2. William Correa, Bombay, to H. Ayers, UCE Hong Kong, 04/10/82. UCC 01736

1. Thousands of our children weren’t so lucky. They survived. Fundraising appeal in The Guardian Dec 3, 1994. Placed by International Medical Appeal for Bhopal, later the Bhopal Medical Appeal by Collett Dickenson Pearce & Partners, writer Indra Sinha, art director Guy Moore
2. Findings and Judgement of the Permanent People’s Tribunal on Bhopal, Oct 1992
3. Statement of the International Medical Commission for Bhopal, Jan 24, 1994
4. Final Report of the International Medical Commission for Bhopal, March 11, 1996

Facsmile of Thousands of our children weren’t so lucky. They survived. Fundraising appeal in The Guardian Dec 3, 1994. Placed by International Medical Appeal for Bhopal, later the Bhopal Medical Appeal by agency Collett Dickenson Pearce & Partners, Writer: Indra Sinha, Art Director: Guy Moore

1. Second report of the Monitoring Committee On Medical Rehabilitation of Bhopal Gas Victims, June 8th, 2005

74-75 3,000 YEAR OLD SCIENCE
1. Observations of the ICMR, Indian Council of Medical Research, February 1985
2. Citizens’ Committee for Relief & Rehabilitation in Bhopal, 1985
3. Medico Friends Study on women pregnant at the time of the gas disaster, Feb 1985
4. Study of Citizens Committee for Relief and Rehabilitation in Bhopal, Mar 1985
5. Daya Varma. Epidemiological &  Experimental Studies on the Effects of Methyl Isocyanate on the Course of Pregnancy, Environmental Health Perspectives, Vol LXXII, pp153-157, September 1985
6. Observations of the ICMR, Indian Council of Medical Research, February 1985
7. Health Effects of the Toxic Gas Leak from the Union Carbide Methyl Isocyanate Plant in Bhopal Technical Report on Population Based Long Term Epidemiological Studies (1985 – 1994), Indian Council of Medical Research (ICMR)
8. Sambhavna Trust 1999-2000

Comparative efficacy of Yoga therapy in treatment of dysmenorrhoea of women exposed to contaminated ground water. Sambhavna Trust, 2008

1. When money is not enough – inadequate health care in Bhopal, Maya Shaw, accessed at
2. 1996 Sambhavna study into mis-prescribing of drugs in government hospitals

Numbers here identify Union Carbide and Arthur D Little documents obtained via discovery in a US court. Full versions of all documents are available on
1. ucc 02271
2. Assessment of pollution damage due to Solar Evaporation Ponds at Union Carbide factory, Bhopal, NEERI report, 1990. The NEERI report shows that it left as many as nine peaks unidentified in a [chromatography] of soil and water samples, NEERI 1990, pp.73-4.
3. ibid­.
4. ucc 02268
5. Norm Gaines, ucc 02050
6. ucc 02400 and 02401. (Full Carbide discussion: ucc 02398 / 02399 / 02400 / 02401 and 02402.)
7. Madhya Pradesh Public Health Engineering
Department’s State Research Laboratory tested water from 11 community tubewells, finding large amounts of chemicals dissolved in the water. ‘It is established that this pollution is due to chemicals used in the Union Carbide factory that have proven to be extremely harmful for health. Therefore the use of this water for drinking must be stopped immediately.’ Confidential report of the Chief Chemist, State Research Laboratory, Madhya Pradesh Public Health Engineering Department, Nov 26, 1996
8. ucc 01099
9. Assessment of Contaminated Areas Due to Past Waste Disposal Practices at EIIL, neeri report1997
10. ucc 01100 / 01101
11. Arthur D. Little critique of neeri draft report, ucc 03043, p.13
12. ibid
13. ucc 03042- 03043
14. NEERI report 1997 op. cit.
15. Krohley Declaration, Para 6, Ex. A

Facts and figures drawn from The Bhopal Legacy, Greenpeace, Nov 1999. Analysis of Chemicals by Greenpeace Laboratory 1999 & 2009
See also related Greenpeace reports available from:

Chemical Stockpiles at Union Carbide in Bhopal.
• Executive Summary, Technical guidelines for cleanup at the Union Carbide India Ltd (UCIL) site in Bhopal, Madya Pradesh, India, 2002
• Corporate Crimes: The need for an international instrument on corporate accountability and liability (2002 Greenpeace report)

1. Greenpeace declares Bhopal site a ‘global toxic hotspot’ Dec 2, 1999
2. Confidential report of the Chief Chemist, State Research Laboratory, Madhya Pradesh Public Health Engineering Department, November 1996
3 & 5. ‘A report issued by the India’s National Environmental Engineering Research Institute (NEERI) in 1997 found … no evidence of ground-water contamination outside the plant and concluded that local water-wells were not affected by plant disposal activities.
4 &5. ‘ In a report to the State of Madhya Pradesh dated June 2010, India’s National Environmental
Engineering Research Institute concluded that the ‘groundwater in general is not contaminated due to seepage of contaminants from the UCIL’ plant site. This conclusion is consistent with NEERI’s earlier findings that all groundwater samples tested were within drinking water standards.’ Dow Chemical Company, Q & A, with respect to the Government of India’s request for a Curative Petition related to the 1989 Bhopal Settlement, Feb 28, 2011, accessed at

Bhopal Group for Information & Action
Children seen by Sambhavna and Chingari clinics

1. Letter of Subimal Bose to Norm Gaines March 30, 1992 revealing that people of Atal Ayub Nagar, whom he described as ‘squatters’, were drinking from wells contaminated by factory chemicals
2. The Bhopal Legacy, Greenpeace, 1999
3. Surviving Bhopal, Factfinding Mission on Bhopal, 2002

Account of meeting and interview with N. Ganesh by Tim Edwards
1. Indian Council of Medical Research study 1980s
2. Bhopal’s health disaster continues to unfold, Dinesh C. Sharma, The Lancet, Vol. CCCLX No. 9336 p. 859, Sept 14, 2002

1. Chemical & Engineering News, Vol 79, No 25, pp. 21-25, June 18, 2001
2. Union Carbide Corporation,Corm 8-k, SEC filing, August 3, 1999
3. London 2012: Dow Chemical deal is fine by me, says David Cameron, Owen Gibson, The Guardian, March 12, 2012.
3a. The FIR (First Information Report) was filed at the city’s Hanumanganj police station on the evening of Dec 3 1984 by Inspector Surinder Singh Thakur. The names of Warren Anderson, Keshub Mahindra, Chairman of Union Carbide India Limited, and Vijay Gokahle, Managing Director (the latter two convicted by Mohan P Tiwari, Chief Judicial Magistrate, Bhopal, on 7 June 2010) do not figure in the FIR. The CBI took over the case on Dec 6 1984, the eve of Warren Anderson’s arrival in Bhopal. Thakur wrote out a charge sheet under section 304A of the Indian Penal Code, naming eleven accused including Warren
Anderson, UCC and UCE as accused nos. 1, 10 & 11 respectively. (See note 9 and above: charge sheet, as produced at commencement of proceedings in Nov 1987)
4. Unfolding the Betrayal of Bhopal Gas Tragedy, Moti Singh, B.R. Publishing Corporation, 2008
5. Rob Hager, lawyer for the Christic Institute, characterised the GAF takeover attempt as ‘a sweetheart operation and intentional smokescreen for fraudulent transfers to UCC shareholders of assets that might otherwise have been subject to a potential Bhopal legal judgement…’ Letter, Rob Hager, Multinational Monitor Vol 12, No 9, Sept 1991
6. In Re Union Carbide Corporation Gas Plant Disaster at Bhopal, India in December, 1984, 634 F Supp 842 (SNDY 1986).
7. UCC tendered acceptance to the court on June 12, 1986. Inconvenient Forum and Convenient Catastrophe, Upendra Baxi, the Indian Law Institute, 1986 p. 326
8. ‘Towe letter’ (reproduced on p.41) by Dr V. Krishna, Adv (C), Secretary, Ministry of Chemicals &
Fertilizers, circulated to Mrs Sarla Grewal, Secretary, Ministry of Health & Family Welfare, and Dr. S. Varendra, Secretary & Director General, Council of Scientific & Industrial Research. File: 21(13)/85-chI
9. Charge Sheet in respect of Crime No. 1104/84, registered on 6th December 1984at Hanumanganj
police station, Bhopal, under Section 304A of Indian Penal Code by Inspector Surinder Singh Thakur ‘who observed­people dying around the factory of Union Carbide (India) Limited, due to escape of some gas from the factory.’ (Above: Charge sheet as produced at commencement of criminal proceedings in Nov 1987)
10. Meeting with MegaVisa Marketing & Solutions ltd on Tuesday 13 Feb 2001. Ravi Muthukrishnan, Dow Chemical Country Manager, India, attachment to email re: ucc Agent/Distributor – India/megavisa dated February 13th, 2001. Doc. no. d14000903 in Civil No. 3:02 CV 1107 (avc), MM Global Services Inc et al v. the Dow Chemical Company & Union Carbide Corporation et al, United States District Court for the District of Connecticut
11. Letter of Agreement, R Natarajan, Vice President, Union Carbide Eastern, to Visa Petrochemicals PVT Ltd, November 14, 1987. Document no. D00619 in Civil No. 3:02 CV 1107 (AVC)
12. India Acts in Carbide Case, Reuters, May 17, 1988
13. The Chief Judicial Magistrate’s Court, Bhopal, issued summons to Peter J Whitley, named representatives of Union Carbide Eastern, on Sept 24, 1988. The Division of Corporations, State of Delaware, records Entity file no. 2174914, Union Carbide Asia Pacific, Inc., registered Oct 11, 1988
14. ‘In 1983, I joined Union Carbide Eastern Inc., and worked for that company in Hong Kong. In 1988, Union Carbide Eastern, Inc. was wound up. I then joined UCAP in January 1989 and moved from Hong Kong to Singapore.’ Affidavit of Lawrence  Cheung, Sales Director of polyolefins and elastomers for Dow Chemical Pacific (Singapore) Pte. Ltd, in Civil No. 3:02 CV 1107 (AVC). In addition,letters of agreement between Visa Petrochemicals and Union Carbide Eastern were subsequently managed by R. Natarajan in his new capacity as President of Union Carbide Asia Pacific (Document D00618)
15. $1000 bailable arrest warrants against UCC Chief, Others, Times of India, Nov 16, 1988
16. Settlement, 14 Feb 1989. ‘To enable the effectuation of the settlement, all civil proceedings related to and arising out of the Bhopal gas disaster shall hereby stand transferred to this Court and shall stand concluded in terms of the settlement, and all criminal proceedings related to and arising out of the disaster shall stand quashed wherever these may be pending.’ Union Carbide Corporation v. Union of India (1989) 3 SCC
17. Attorney General Soli Sorabjee alleged that the inspection was due to be conducted during the middle of February, 1989 and that the settlement ‘was intended to circumvent that inspection…’ Union Carbide Corporation vs respondent: Union of India, 03/10/1991
18. This old story finds its latest airing in journalist Anjali Deshpande’s 2012 novel Impeachment, about the aftermath of the 1989 Union Carbide settlement
19. Oct 3, 1991, Indian Supreme Court modifies 1989 Settlement, revives criminal charges against UCC, UCE & Warren Anderson and offers UCC its money back: Union Carbide Corporation v. Union of India (1991) 4 SCC 584
20. ibid.
21. Court threatens attachment, Order of Feb 1, 1992, CJM, Bhopal in M.J.C. No.91/1992
22. The proclamation appears in the Washington Post Classifieds under an ad offering ‘Trash Removal’
23. ‘At the next hearing on March 27, 1992, the prosecution (CBI) moved an application for
attachment of the property of the absconding foreign accused but at the request of the counsel for the
Indian co-accused the case was adjourned to April 30, 1992.’ S. Muralidhar, Unsettling Truths, Untold Tales International Environmental Law Research Centre Working Paper, 2004/5, 3.2.1,
24. ‘The request for issue of non-bailable arrest warrants against Warren Anderson for the purposes of extradition was to be considered on May 22, 1992. In this interregnum, UCC managed to create the Bhopal Hospital Trust and endow its entire shareholding in UCIL to the BHT.’ ibid.
25. ‘…the accused wants to evade prosecution by any means. Then there is no option but to attach its
properties situated in India.’ Order April 30, 1992 passed by the CJM, Bhopal in M.J.C. No.91 of 1992.
26. Order, dated December 10, 1993, Supreme Court in I.A.Nos.24-25 in C.A.Nos.3187-88 of 1988
27. ibid.
28. ibid. p.7
29. Ahmadi bench overrules Bhopal court: Order dated February 14, 1994 of the Supreme Court in C.A.Nos.3187-88 of 1988
30. ‘The victim groups on getting to know of this order, filed review petitions on April 13, 1994 for
recall of the order dated February 14, 1994. These applications were adjourned on five occasions and were ultimately heard on October 20, 1994 by which time, the sale of the shares had already taken place.’
S. Muralidhar, Unsettling Truths, Untold Tales, p.33
31. ibid
32. See the orders dated October 20, 1994 passed by the Supreme Court reported in Union Carbide Corporation v. Union of India (1994)
33. I.A.Nos.30-31 of 1995 in C.A.Nos.3187-88 of 1988, prayer (a).
34. Union Carbide Corporation v. Union of India (1996) 3 SCALE (SP) 64
35. Preparing for Growth, ICIS News, June 19th, 1995, accessed at 2380/preparing-for-growth.html
36. UCC Megavisa relationship in India, Ravi Muthukrishnan, Document no. D14000904 in Civil No. 3:02 CV 1107 (AVC
37. Defendants’ Brief in support of their motion for summary judgment, Dow Chemical et al, January 23rd, 2006, p. 1. In Civil No. 3:02 CV 1107 (AVC)
38. ‘In a well orchestrated move, UCIL on August 24, 1995 withdrew its revision petitions in the Madhya Pradesh High Court challenging the attachment order passed by the CJM, Bhopal on April 30, 1992. Thus, the attachment order attained finality and so did the finding of the CJM, Bhopal in that order that the creation of the Trust was malafide and with a view to defeat the attachment order.’ S. Muralidhar, Unsettling Truths, Untold Tales, p.33
39. Union Carbide Corporation, form 8−k, filed with the Securities and Exchange Ccommission, August 3, 1999 40. Martin F Statfeld on behalf of himself and all others similarly situated, v. Frank Popoff et al, 00CIV. 3364 filed May 3rd, 2000 in United States District Court, Southern District of New York
41. Shadow of Bhopal heading for Dow, Beth Medley Bellor, Midland Daily News, May 12, 2000
42. Dow completes Carbide deal, Chemical & Engineering News, Feb 12, 2001, Vol 79, No 7, p.7
43. Michael McCoy, Chemical & Engineering News, Vol 79, No 25, pp. 21-25, June 18, 2001
44. Email, Re. Reference to Dow/Union Carbide, Catherine Maxey, Business Public Affairs Director, Performance Chemicals, Dow Chemical Company, March 14, 2001.
45. ‘Dow conducts its worldwide operations through global businesses, and the Corporation’s business activities comprise components of Dow’s global businesses rather than stand-alone operations. Because there are no separable reportable business segments for UCC and no detailed business information is provided to a chief operating decision maker regarding the Corporation’s stand-alone operations, the Corporation’s results are reported as a single operating segment. In addition, in order to simplify the customer interface process, the Corporation sells substantially all its products to Dow.’ Union Carbide Corporation, Annual Report on Form 10-k/a Year Ended Dec 31, 2011, Part 1.
46. Dow Chemical defends Olympic Stadium sponsorship deal, Owen Gibson in The Guardian, March 8, 2012