Local families, along with the Paris branch of the CGT union and the anti-pollution association Henri Pezerat, have filed the complaint alleging that the city and public health authorities put lives at risk.
“Despite the magnitude of the fire and knowledge about the risk of pollution and contamination … the authorities involved did not take any particular precautions for more than three months after the fire,” according to a copy of the complaint seen by AFP.
It says that 400 tons of lead from the roof of the Gothic masterpiece melted or dispersed as microparticles over the French capital during the fire on April 15, 2019.
“Children (in nurseries and schools), neighbors and workers have clearly been exposed to the risk of lead contamination,” the complaint adds. “These facts amount to the crime of endangering the lives of others.”
The plaza in front of the cathedral, which is being rebuilt, was closed to the public again in May this year after tests revealed high concentrations of toxic lead particles.
Several months after the fire, city authorities ordered a thorough cleaning of schools in the area, while urging children and pregnant women to have blood tests.
The complaint says the city, led by socialist mayor and aspiring president Anne Hidalgo, withheld information from school principals and did not act promptly.
It also addresses the police department, the ministry of culture and the regional health authorities.
While the Notre-Dame spire collapsed and much of the roof was destroyed, efforts by firefighters ensured that the great medieval building survived the fire.
But the lead risks delaying debris clearance work and the launch of the landmark restoration effort, which President Emmanuel Macron wants to open for visitors in time for the 2024 Olympics in Paris.
Investigators have yet to determine the cause of the fire, but have said that an accident, possibly caused by a short circuit or a discarded cigarette butt, remains the most likely explanation.