Rylands v. Fletcher Brief (1868)

Rylands v. Fletcher
In the Exchequer, England (1868)

Facts: Defendant constructed a reservoir to supply water for his mill. Defendant employed independent contractors and engineers to excavate and build the reservoir. While excavating, the defendant’s contractors found several old mine shafts which had been filled with soil. The shafts were actually connected to the plaintiff’s mines through a series of interconnecting tunnels. Days after the resevoir’s completion, while it was partially filled, one of the shafts collapsed, which allowed the reservoir to flood the plaintiff’s mines.

Issue: Whether the doctrine of strict liability should be applied to inherently dangerous activities in the same way as was applied in nuisance and cattle trespass?

Holding: Yes

Decsion: Verdict for plaintiff. The Court found in favour of Fletcher and ordered Rylands to pay for all the property damage to the mine. The Court agreed that Rylands had a duty in maintaining the reservoir and of being liable for all harm caused by it with broad scope of liability. In non-natural uses, a defendant is strictly liable to a neighbor if the substance escapes. For natural accumulations, there is no liability for escape.

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