CASE BRIEF

RYLANDS V. FLETCHER (1868) LR 3 HL 330

FACTS:

In 1860, Thomas Rylands commissioned the construction of a force on his property, intending it to supply water to Ainsworth Mill. exercising independent contractors, the force was erected over land containing old coal shafts connected to Thomas Fletcher's touching mine. These shafts weren't duly sealed by the contractors, and when the force was filled for the first time in December 1860, it burst, submerging Fletcher's Red House Colliery and causing£ 937 in damages. Fletcher pumped out the water, but in April 1861, his pump burst, leading to a renewed flooding of the mine. An examination revealed the neglected coal shafts, egging Fletcher to file a claim against Rylands and squatter Jehu Horrocks on November 4, 1861. The posterior legal proceedings crowned in the case of Rylands v Fletcher( 1868) LR 3 HL 330. Despite Rylands playing no active part in the construction and the absence of negligence on his part, the House of Lords affirmed the decision of the Court of Exchequer Chamber, holding Rylands liable for the damages caused by the force's burst. This case established the principle that a person who brings commodity onto their land that's likely to do mischief if it escapes, indeed without negligence, is rigorously liable for any performing damages.

ISSUES:

1. Was there any form of Nuisance present ?

2. Did the use of the defendant's land amount to an unreasonable act, and therefore, should they be held responsible for the damages suffered by the plaintiff?

JUDGEMENT:

Court of Liverpool

Judgment favored the defendant, stating there was neither trespass nor nuisance. The flooding was considered non-direct and non-continuous. The adjudicator appointed later also ruled in favor of the defendant, holding the contractors liable for negligence. Court of Exchequer of Pleas.

Court of Exchequer of Pleas

Decided on two issues liability for the contractors' conduct and liability for damage despite the lack of negligence. Unanimously declared the defendant not liable for the contractors' conduct. still, disunited views on the alternate issue.

The majority (Pollock CBJ. and Martin BJ.) held the defendant not liable due to the absence of negligence. Differing ( BramwellB.J.) opinion held the defendant liable for trespass and nuisance.

Court of Exchequer Chamber

Capsized the decision of the Court of Exchequer of Pleas. Introduced the rule of strict liability a person bringing commodity onto their land, likely to beget mischief if it escapes, is prima facie answerable for performing damage, irrespective of negligence, knowledge, or intention. Exceptions like Acts of God or Plaintiff's own dereliction were banned but were supposed irrelevant in this case.

House of Lords

Dismissed the appeal, affirming the decision of the Exchequer Chamber but handed further granularity to the rule of strict liability. Stated that for strict liability to apply, the land from which escape occurs must have been modified in a Non-natural, unusual, or inappropriate way. The use of the land should be Non-natural for strict liability to be applicable.

CONCLUSION:

The House of Lords upheld the rule of strict liability, adding the condition of" synthetic use of land" for its connection, thereby establishing a corner legal precedent in the case of Rylands v Fletcher.