Overview:
In this case, the House of Lords recognized the Rylands v. Fletcher rule, a general law principle of strict liability for damages arising by escape of dangerous substances brought onto one's land. The person who causes damage to another person either doing the act intentionally or negligently will be held liable to pay damages to the plaintiff.
However, this rule of strict liability leads to many problems. For example, if I store some explosive material in my premises to do some experiment and it explodes without my negligence or knowledge on its own.
The question arises - Can I be held liable? absolutely not, because there was absence of intention to cause any harm as well as there was no negligence. This rule was propounded by the House of Lords in Rylands v/s Fletcher case to absurd the problem of liability. Occasionally, it is known as the "Rule of Strict Liability" in the legal field. According to this, the defendant could be liable even if there is no negligence on his part.
Case Details
| Case Name | Rylands v Fletcher |
| Case Number | UKHL 1, L.R. 3 H.L. 330 |
| Jurisdiction | House of Lords |
| Bench | Lord Cairns and Lord Cranworth |
| Date of Judgement | July 17, 1868 |
Facts of the Case
Rylands (defendant) constructed a reservoir on his land for restoring the water and providing to his mill through an independent contractor. There were few old disused shafts under the reservoir which he failed to fix.
Accordingly, those shafts remained unblocked. When the reservoir filled with the water, there is a burst through the defected shafts and it flooded the coal mines of the plaintiff. Despite the fact, there was no negligence on the part of the defendant, the plaintiff (Fletcher) sued Rylands for compensation.
Issues:
Essentials of Strict Liability
Along with Rylands v. Fletcher case, many other various cases are helpful to developments regarding the rule of strict liability. Apart from this liability there are several exceptions. For example - Act done by third parties and Statutory authority were included in this rule. The essentials for the application of this rule are discussed below:
1. Dangerous Substance:
The first crucial rule is the presence of a dangerous thing or substance. A person can be held liable, if the thing which he had stored was dangerous. The danger thing can fluctuate or be determined on the basis of facts and circumstances. There are several examples of dangerous things - poisonous trees, rusty wire, explosives, noxious fumes etc.
2. Unnatural Use of the Land:
It is also of the required thing for applicability of strict liability. Unnatural use of land is explained as "some special use that brings danger to others". It must not solely by ordinary use of land or general usage of the property.
For example - if you grow a poisonous tree at your premises that it will be considered as unnatural use of the land. Accordingly, If anyone causes damage by that tree then, he will be liable for damages.
3. Escape:
The last requirement for this liability is escaping the things. The substance must be dangerous and escape from the property of the defendant. It is essential to escape the dangerous thing, if not escape and damage is still caused the defendant can not be held liable.
For example, if any person brought an explosive material at home. While doing some experiments with these explosives. The material suddenly exploded and injured an employee who worked with him. Here, the defendant will not be held liable under the rule of strict liability because there is no escape of the substance outside your premises.
Cases in favour of defendant
1. Smith v. Kenrick:
The plaintiff and defendant adopted mine on the adjacent land. The defendant dug holes in the ordinary mining process as a result of which, the water went out from the holes and then went into the plaintiff's mine as a result, triggering damage.
It was held by the court that the defendant was not liable because each person had a right to work in his own mine in the best method for his benefit. If he did so without any negligence, he was not liable to others for prejudice to his property which might thereby arise.
2. Partridge v. Seott:
In this case, the defendant implemented some skillful persons to perform a lawful act. But some damage to the plaintiff owing to the negligence of the implemented ones. It was held that the population who essentially had done the work alone were liable.
3. Chadwick v. Trover:
In this case, a person pulled down his own wall without giving a notice to his neighbour. Even the defendant was not legally bound to do so and thus damage was caused.
The defendant had no knowledge about this wall causing harm. It was held that the man was not liable as there was no knowledge present on his part by doing that act.
Summary of the Case:
There was two parties involved in this case :-
1. Thomas Fletcher - coal mine operator
2. John Rylands - mill owner
A reservoir was constructed by Rylands that is placed just adjacent to the Fletcher’s coal mine. However, Ryland built it in own land in order to produce the water supply to their mill. Unfortunately, the reservoir broke or collapsed as a result of Fletcher's mine being flooded. To recover the amount of losses, Fletcher filed a suit against Rylands.
Conclusion
This Landmark judgment has established the term called “strict liability” and in torts this became very popular. The rule came into existence for solving the disputes where the harm is caused without any negligence. In this era of industrialization and technology. It is important to make the owner liable, who uses dangerous things and that things cause damage to another person.
This liability has an objective to make the owner responsible for its dangerous things. It creates a burden on the owner to take the responsibility of all calamity which may be caused by the dangerous thing that he has owned.
