Rylands v Fletcher (1866) LR 1 Exch 265

Facts

  • Rylands constructed a reservoir on his land for industrial purposes.
  • Fletcher owned neighboring coal mines that were flooded after water from the reservoir escaped.
  • The escape resulted in significant damage to Fletcher’s property.
  • The reservoir’s construction and maintenance did not involve negligence.
  • The incident occurred during a period of rapid industrial growth, where increased use of land for industry led to new legal disputes over hazardous materials.

Issues

  1. Whether a person who lawfully brings onto their land a dangerous substance is liable for damage caused if that substance escapes, even absent negligence.
  2. Whether the construction of a reservoir for industrial use constituted a non-natural use of land.
  3. Whether liability should be based on strict liability or limited to fault-based principles such as negligence or nuisance.

Decision

  • The court held Rylands strictly liable for the escape and resulting damage, despite the absence of negligence.
  • The reservoir was found to be a non-natural use of the land due to its potential to cause harm if the stored water escaped.
  • Liability was imposed because the escape of the hazardous substance (water) caused foreseeable harm to a neighboring property owner.
  • The decision established that bringing dangerous substances onto land entails responsibility for damages caused by any escape.

Legal Principles

  • Established the principle of strict liability for the escape of dangerous substances from land.
  • Liability applies when there is a non-natural use of land and the escape of a hazardous material causes foreseeable harm.
  • Negligence or intent is not required; the mere escape and resulting damage is sufficient.
  • The principle has influenced environmental, industrial accident, and property dispute case law.

Conclusion

Rylands v Fletcher set the enduring rule of strict liability for landowners who undertake non-natural uses involving dangerous substances, making them liable for any damage caused by their escape, regardless of negligence. This doctrine continues to influence tort law, although subsequent case law and criticism have refined its scope and application.

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