Rylands v Fletcher

Factual and Procedural Background

The Plaintiff operated a coal mine beneath a parcel of land. The Defendant, who owned a nearby mill, constructed a reservoir on adjacent land in order to store water for industrial use. Beneath the Defendant’s land lay a network of disused vertical and horizontal mine shafts that were unknown to the parties and imperfectly filled with soil and debris. After the reservoir was filled, water broke through the disused shafts, travelled through the underground passages, and flooded the Plaintiff’s mine, causing substantial damage.

The Plaintiff sued for damages. The Court of Exchequer held that no cause of action had been established. On appeal, the Court of Exchequer Chamber unanimously reversed, ruling in favour of the Plaintiff. The Defendant, now styled “Plaintiff in Error,” appealed to the House of Lords. The House of Lords (with opinions delivered by Judge Cairns and Judge Cranworth) dismissed the appeal.

Legal Issues Presented

1. Whether a landowner who, for non-natural purposes, brings or accumulates water on his land is strictly liable for damage caused when that water escapes onto a neighbour’s land, irrespective of negligence.
2. Whether the existence of hidden defects (the unknown, disused mine shafts) absolved the Defendant from liability.

Table of Precedents Cited

Court's Reasoning and Analysis

Judge Cairns. The Court drew a critical distinction between the natural and non-natural use of land:

• If a landowner merely allows water to follow its natural course, a neighbour must protect himself.
• Conversely, when a landowner, “for his own purposes,” brings onto his land something likely to cause mischief if it escapes, he must “keep it in at his peril.”

Because the Defendant accumulated a large body of water for industrial purposes—an activity characterised as “non-natural”—the Defendant was strictly liable for any escape, irrespective of personal participation, knowledge, or care. The only potential defences would be the Plaintiff’s own default or an act of God (vis major), neither of which was present.

Judge Cranworth (concurring). Adopting the same strict-liability principle, Judge Cranworth emphasised that the decisive inquiry is not the Defendant’s level of caution but whether the Defendant’s act caused the damage. He analogised the case to Baird v Williamson, noting that the Defendant’s positive act—storing water—directly produced the flooding. Accordingly, liability followed, even though the disused shafts were unknown.

Holding and Implications

HOLDING: Appeal dismissed; judgment of the Court of Exchequer Chamber affirmed. The Defendant is liable for the Plaintiff’s damages.

Implications: The decision establishes the strict-liability rule now associated with the case’s name: a person who, for non-natural purposes, brings onto land anything likely to cause harm if it escapes must confine it at his peril. This principle has become a foundational doctrine in English tort law, imposing liability without proof of negligence for certain hazardous activities.