## Facts

- Mill owners constructed a large artificial reservoir on their land to supply water for their business.
- Independent engineers and contractors built the reservoir.
- Unknown to the owners, the site overlay old, disused mine shafts and workings that had been imperfectly filled or blocked.
- A neighboring landowner operated an active coal mine.
- When the reservoir was filled, water escaped through the old mine workings and flooded the neighboring mine, causing substantial damage.
- A factfinder concluded that contractors were negligent in addressing the old workings, but the owners lacked personal knowledge of the defect and had engaged apparently competent contractors.

## Issues

1. Whether a landowner who, for his own purposes, accumulates a thing likely to cause harm if it escapes is liable for resulting damage upon escape, even without negligence or personal fault.
2. Whether maintaining a large artificial reservoir in the relevant locality constituted a “non-natural use” of land sufficient to impose strict liability.

## Decision

- The House of Lords affirmed judgment for the neighboring mine operator and held the reservoir owners liable.
- Liability attached even though the owners were not personally negligent and had employed competent contractors.
- The Court treated the reservoir as a non-natural use of land that created an increased risk to neighbors.
- The owners were prima facie responsible for damage that was the natural consequence of the escape of the accumulated water.

## Legal Principles

- A person who, for his own purposes, brings onto and keeps on his land something likely to do mischief if it escapes must keep it in at his peril.
- If that thing escapes from the defendant’s land and causes damage to another’s land, the defendant is prima facie liable without proof of negligence.
- The rule applies only where the accumulation results from a non-natural (special or extraordinary) use of land that increases danger to others.
- Elements commonly stated include: (1) accumulation or bringing onto land, (2) non-natural use, (3) likelihood of mischief upon escape, (4) escape from the defendant’s land, and (5) resulting damage.
- The doctrine developed in close relation to private nuisance concepts and has been treated in later authority as a strict-liability form of nuisance rather than a wholly independent tort.
- Recognized limits and defenses (as later developed) include consent, extraordinary natural events, unforeseeable acts of third parties, statutory authorization, and plaintiff’s fault.

## Conclusion

The House of Lords established strict liability for harm caused when a defendant, making a non-natural use of land, accumulates a potentially harmful thing that escapes and damages a neighbor, making negligence unnecessary once the rule’s conditions are met.


Rylands v. Fletcher, L.R. 3 H.L. 330 (H.L. 1868)