Rylands v Fletcher (1868)

Author: Janhavi Pradhane, Shahaji Law College

Introduction

Case Name:  John Rylands and Jehu Horrocks v Thomas Fletcher

Case Citation: The citation for Rylands v Fletcher is (1868) UKHL 1, (1868) LR 3 HL 330

Court: The case Rylands v Fletcher was heard in the House of Lords

Date of judgement: The case was decided on July 17, 1868.


Rylands v Fletcher was one of the landmark case, decided by House of Lords in the law of tort. the word tort is derived from the Latin word which means “wrong.” Tort In English common law is a negligence. Which occurs when someone causes an injury or a loss to another due to their careless act or behaviour. The general rule is that the person who causes such an injury shall pay damages or compensation to the affected party.
The case established the rule that when someone’s non-natural use of their land causes damage to another’s land, the person is strictly liable. The case established the principle of strict liability in English tort. This principle holds that people can be held responsible for damage caused by hazardous activities on their property, even if they were not negligent or did not intend to cause harm.


Background

The case involved a dispute between two landowners, Rylands and Fletcher:

Rylands: The Thomas Rylands (defendant) Owned a mine and employed contractors to build a reservoir on his land

Fletcher: John Fletcher (Plaintiff) Owned a neighbouring property and ran a coal mine.

The lawsuit: In case Plaintiff initiated legal action against defendant for damage caused to his coal mines due to the defendants employed independent contractors to construct a reservoir on their land.


Facts of the case:

In 1860, Rylands paid to an independent contractors to build a reservoir on his land, intending that it should supply the Ainsworth Mill with water.


Rylands played no active role in the construction, instead, he hired a skilled engineer to handle it.
While building it, the contractors discovered a series of old coal shafts and passages under the land filled loosely with soil and breakage, which joined up with Thomas Fletcher’s adjoining mine. Rather than blocking these shafts up, the contractors left them.


On 11 December 1860, shortly after being filled for the first time, Rylands’ reservoir burst and flooded Fletcher’s mine, the Red House Colliery, causing of damage.


Fletcher pumped the water out, but on 17 April 1861 his pump burst, and the mine again began to flood.


At this point a mines inspector was brought in, and the sunken coal shafts were discovered. Fletcher brought a claim against Rylands and the landowner, on 4 November 1861.


Issues Raised
Whether the defendants were liable for the actions of the contractors.
Whether the defendants were liable for the damage regardless of their lack of negligence.
Whether the plaintiff was eligible to receive damages from the defendant.


Observations

The House of Lords affirmed the decision of the Court of Exchequer Chamber, ruling in Favor of the plaintiff.

The court established what became known as the rule in Rylands v Fletcher: a person who brings onto their land and collects and keeps there anything likely to do mischief If something escapes, they must take responsibility for it and ensure it doesn’t cause harm. If it does escape, they are automatically held accountable for any damage that naturally results from it.
This ruling effectively established a principle of strict liability for certain activities.
Strict liability means that a party can be held liable for damages regardless of fault or intent.
Under this principle, the defendants were held liable for the damage caused by the escape of water from their reservoir, even though they had not been negligent in its construction or operation.


The court emphasized that in such cases, the question is not whether the defendant acted with due care, but whether their acts occasioned the damage.


The court reasoned that when one person, in managing their own affairs, causes damage to another, even innocently, it is just that they should be the party to suffer the consequences.
This case established a form of strict liability for certain activities that are deemed to be especially dangerous or inappropriate for the area in which they occur, setting a precedent in tort law that continues to be influential.


Judicial Proceedings
The case was first heard by the Court of Exchequer, where the court ruled in favor of Fletcher.
The decision was appealed to the Court of Exchequer Chamber, which upheld the ruling.
Finally, the House of Lords delivered the definitive judgment, establishing the doctrine of strict liability.


Arguments for the Plaintiff (Fletcher)

Duty of Care:
Fletcher argued that Rylands had a responsibility to make sure the reservoir built on his property wouldn’t cause harm to nearby land. Since the reservoir could potentially flood nearby areas, Rylands should have taken steps to prevent that from happening.


Negligence by Contractors:
Even though Rylands hired independent contractors to build the reservoir, Fletcher argued that Rylands was still responsible for what happened. The contractors didn’t notice or fix old, abandoned mine shafts under the reservoir, which caused water to escape.


Non-Natural Use of Land:
The plaintiff argued that creating a reservoir on the land for personal use was not a normal or natural way to use the land. By adding something risky, like a large amount of water, onto the land, Rylands took on the responsibility for any damage or harm it might cause.


Strict Liability Principle:
The plaintiff argued that even in the absence of negligence, Rylands should be held strictly liable for the damage caused by the reservoir’s failure. The principle of strict liability holds individuals accountable for harm caused by activities they initiate, regardless of intent or fault.


Arguments for the Defendant (Rylands)
Absence of Negligence:
Rylands contended that he had exercised due diligence in hiring competent contractors to construct the reservoir. Since the failure was due to the contractors’ oversight, Rylands argued he should not be held personally liable.


Independent Contractors:
Rylands argued that he hired independent contractors to build the reservoir, and it was their job to make sure it was safe. He argued that since the contractors were responsible for the work, their failure to find the old mine shafts should not be blamed on him.


Natural Use of Land:
Rylands maintained that the construction of the reservoir for agricultural and personal use was a natural and reasonable use of his land. He argued that the activity didn’t involve any unusual or dangerous risks.


Unforeseeable Event:
The flooding was argued to be an unforeseeable event due to the unknown presence of the old mine shafts.


Ruling

The House of Lords ruled in Favor of Fletcher and establishing the principle of strict liability:
If a person brings onto their land something likely to cause harm if it escapes, they are liable for any damage caused or to pay compensation. This applies even if they took reasonable care to prevent such an escape. The judgment emphasized that non-natural use of land carries inherent risks, making the defendant responsible for any resulting damage. But there are certain exceptions such as acts of God, the plaintiff’s own fault, or interference by third parties.


Key Aspects of the Case:


No Fault Liability: The key point in this case was that Rylands was held responsible even though he was not careless. This is called strict liability, where someone is legally accountable for the results of an activity, even if they didn’t make a mistake or mean to cause harm.


Use of Land: If someone brings something onto their land that could cause harm if it escapes, they are responsible for any damage it causes.
“Non-natural” Use of Land: Storing a large amount of water in a reservoir was considered an unusual use of land that increased the risk of harm to others.

The Rylands v Fletcher case stands as a cornerstone in the development of strict liability under the law of torts. It underscores the necessity of holding individuals accountable for non-natural uses of land that pose a risk to others. Over time, this principle has been refined and expanded to address modern challenges arising from industrialization and technological advancements, reflecting its enduring relevance.


FAQS


1. What is the significance of the case Rylands v Fletcher?
The case established the principle of strict liability in tort law. This means that a person can be held responsible for damage caused by hazardous activities on their property, even if they were not negligent or had no intent to cause harm.


2. What is “strict liability”?
Strict liability is a legal doctrine where a person is held liable for the consequences of their actions or activities, regardless of their intent or negligence, if such activities cause harm to others.


3. What does “non-natural use of land” mean in this case?
Non-natural use refers to a special or unusual use of land that increases the risk of harm to others. In this case, building a reservoir was considered a non-natural use because it introduced a hazard (a large body of water) that posed risks to neighbouring properties.


4. What issues were raised in the case?
Whether Rylands was liable for the actions of the independent contractors.
Whether Rylands was liable for the damage despite no negligence on his part.
Whether Fletcher was entitled to compensation for the damage.


5. What exceptions to strict liability were mentioned in the ruling?
The court recognized the following exceptions to strict liability:
Acts of God (natural disasters).
Fault of the plaintiff.
Interference by third parties.


References


1.https://en.wikipedia.org/wiki/Rylands_v_Fletcher


2.https://www.lawteacher.net/cases/rylands-v-fletcher.php


3.https://www.lawteacher.net/cases/transco-v-stockport.php


4. Legal journals and textbooks on tort law for case analysis.

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