On September 26, 2022, a fire broke out at the loading dock in the basement of Outlet H in Daejeon, likely caused by the overheating of a refrigerated truck’s exhaust system. As a result, seven workers lost their lives, and one sustained serious injuries. All of the victims were employees of a subcontractor for Department Store H.

Company M (Defendant), the subcontractor responsible for facility management at the outlet, was investigated for failing to properly prepare an emergency response manual, as required under Article 4 of the Enforcement Decree of the Serious Accidents Punishment Act (SAPA) to ensure safety and health, which contributed to a serious accident. However, the investigation concluded that Company M had prepared a serious accident response manual and the prosecution decided not to file charges.

During the investigation, DR & AJU contended that Company M's CEO, who is responsible for headquarters management, should not be deemed negligent for preparing the required emergency response manual under the SAPA solely because the emergency evacuation route (emergency exit) at the outlet, one of the many workplaces (worksites) for Outlet H nationwide, was not specifically marked in the manual. This case is significant as the prosecution acknowledged that there had been a reasonable execution of the obligation to prepare an emergency response manual under Article 4(8) of the Enforcement Decree of the SAPA.