Rylands v Fletcher (1868) LR 3 HL 330 is one of the most significant decisions in the development of English tort law. The case established the principle of strict liability for the escape of hazardous materials from land, even in the absence of negligence.
This landmark ruling created what is commonly known as the rule in Rylands v Fletcher, and it continues to influence modern environmental and nuisance law. The decision is regarded as a specialised form of nuisance, where a defendant may be held liable for damage caused by the escape of a dangerous substance brought onto their land.
Facts of Rylands v Fletcher Case
In Rylands v Fletcher, the defendants employed independent contractors to construct a reservoir on their land to supply water to their mill. During the excavation, the contractors discovered old, disused mine shafts but failed to seal them properly. Once the reservoir was completed and filled with water, the water escaped through the unsealed mine shafts and flooded the neighbouring mines belonging to the plaintiff, Thomas Fletcher.
Fletcher operated coal mines on adjoining land, which were severely damaged as a result of the flooding. He brought legal action against John Rylands, the mill owner, seeking damages for the loss caused by the escape of water from Rylands’ reservoir. The trial court at Liverpool Assizes found in favour of Fletcher, and the Court of Exchequer Chamber affirmed the decision. Rylands appealed to the House of Lords, which upheld the earlier rulings, confirming the defendant’s liability.
Issues
The main issue before the court in Rylands v Fletcher was whether the defendant, Rylands, should be held liable for the damage caused by the escape of water from his land, even though there was no evidence of negligence or direct fault on his part. The case raised the question of whether a person who lawfully brings something onto their land, which later escapes and causes harm, can be held responsible under the principles of nuisance and strict liability.
Rylands v Fletcher Judgement
The House of Lords, affirming the Court of Exchequer Chamber, held Rylands liable. The judgement delivered by Blackburn J in the Exchequer Chamber became the foundation of the rule. He stated that:
“A person who for his own purposes brings on his lands and collects and keeps there anything likely to do mischief if it escapes, must keep it in at his peril; and, if he does not do so, is prima facie answerable for all the damage which is the natural consequence of its escape.”
The court concluded that the storage of large quantities of water in a reservoir was a non-natural use of land and that the escape of water, which caused damage to another’s property, rendered Rylands strictly liable. Lord Cairns LC in the House of Lords emphasised that liability would only arise where there was a non-natural use of land.
Thus, Rylands v Fletcher established that even in the absence of negligence, a person who introduces onto their land something likely to cause harm if it escapes is responsible for any damage resulting from that escape.
Conclusion
In conclusion, Rylands v Fletcher (1868) LR 3 HL 330 established an enduring principle of strict liability, marking a major milestone in English law. The rule holds that a person who brings onto their land something likely to cause harm if it escapes must keep it at their own risk. If it escapes and causes damage, they are liable, even without negligence.
Through this judgement, the courts in Rylands v Fletcher recognised the need to balance individual rights with societal safety, particularly in an era of industrialisation. The case remains an essential precedent in understanding the scope of nuisance, strict liability, and the responsibility that accompanies the use of land.