Rylands v Fletcher [1868] LR 3 HL 330 Case Summary

KEY POINTS

A person who brings onto their land and keeps there anything that is likely to do mischief if it escapes is strictly liable for any damage that results from its escape, even if they took all reasonable precautions.
While the ruling in this case imposes strict liability, it also admits of exceptions, such as acts of God and acts of a third party. If the escape of the dangerous thing is due to these factors, a defendant may not be held liable.

The Defendants, owners of a mill, planned to build a reservoir near the Plaintiff's land. Below the Defendants' land were old mining passages and shafts that had been filled with soil and debris. The Plaintiff's mining activities eventually connected with these abandoned works.
The Defendants constructed the reservoir with the help of engineers and contractors who didn't take proper care given the filled shafts. When the reservoir was filled with water, the pressure caused the old shafts to break, flooding the Plaintiff's mine and causing significant damage.
The initial court ruled in favour of the Defendants, but the Court of Exchequer Chamber unanimously concluded that the Plaintiff had a valid claim for damages.

This case continues to have an impact on tort law, particularly in situations where there is environmental damage, risky behaviour, or property damage brought on by dangerous material escapes.
When certain requirements are met, it serves as a precedent for imposing strict responsibility, but its application frequently necessitates careful analysis of the unique facts and circumstances of each case.

Defendant had permission to build a water mill on his land and employed reputable engineers to do it. The engineers came across some old mine shafts during the work but didn’t seal them properly with the result that water from the mill flooded the mine on the neighbouring land.
HL held Plaintiff liable for the engineers’ lack of care - strict liability.

In cases where damage is done by the operation of nature, e.g. if water had naturally accumulated, Defendant would not be liable.
However, where Plaintiff brings something onto his land which is not there naturally, and, as a result of the imperfect manner in which they do so, then the defendant’s actions were at his own peril. If therefore an evil arises which injures Plaintiff or Plaintiff’s land, Defendant is liable.
He endorses Blackburn J’s decision in the court below.

A person who brings something onto his land likely to do mischief if it escapes must keep it at his peril. He is prima facie liable for any damage naturally consequent upon its escape. He can escape liability where Plaintiff caused the escape or vis maior or an act of god.
This is just: If A’s cattle escapes and ruins B’s crops, then A should pay. Same is true, for example, of filth from one’s privy or fumes, et.c

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