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

Introduction

• This case established the principle of strict liability as a stringent liability of a person even when there is no negligence.
• The principle of strict liability established in this case was seen as a departure from the usual negligence standard in tort law, creating a higher standard of care for potentially dangerous activities.

Facts

• The plaintiff was the occupier of a mine and worked under a close of land.
• The defendants owned a mill in the neighborhood of the plaintiff's mine.
• The defendants decided to construct a reservoir on their land to store water for use in their mill. This land was near, but not directly adjacent to, the plaintiff's land.
• Underneath the defendants' land where they planned to build the reservoir, there were old, disused mining passages and works. These included five vertical shafts and some horizontal shafts connecting them.
• These old mining passages and shafts had been filled with soil and rubbish. Their existence was not known to anyone at the time.
• As the plaintiff had been working his mine, he had gradually worked through coal seams underneath his land and had come into contact with these old, disused works beneath the defendants' land.
• The defendants proceeded with the construction of their reservoir. They employed an engineer and a contractor to design and build it.
• The defendants themselves took no personal part in the works and were unaware of any potential security issues.
• When the reservoir was filled or partially filled with water, the weight of the water pressed down on the improperly filled vertical shafts.
• The water broke through these shafts, flowed down into the horizontal workings, and then passed into the plaintiff's mine workings.
• This flooding caused considerable damage to the plaintiff's mine.
• As a result of this damage, the plaintiff filed a legal action against the defendants.
• The case was first heard in the Court of Exchequer.
  • This court ruled in favor of the defendants, finding that the plaintiff had not established a cause of action.
• The plaintiff appealed this decision to the Court of Exchequer Chamber.
• The Court of Exchequer Chamber reversed the lower court's decision, unanimously finding that there was a cause of action and that the plaintiff was entitled to damages.
• The defendants then appealed this decision to the House of Lords, leading to the final judgment in the case.

Issue Involved

• Whether the acts of the defendants have occasioned the damage?

Observations

• The House of Lords affirmed the decision of the Court of Exchequer Chamber, ruling in favor of the plaintiff.
• The court established what became known as the rule in Rylands v Fletcher: a person who brings onto their land and collects and keeps there anything likely to do mischief if it escapes, must keep it in at their peril. If it escapes, they are prima facie answerable for all the damage which is the natural consequence of its escape.
• This ruling effectively established a principle of strict liability for certain activities.
  • Strict liability means that a party can be held liable for damages regardless of fault or intent.
• Under this principle, the defendants were held liable for the damage caused by the escape of water from their reservoir, even though they had not been negligent in its construction or operation.
• The court emphasized that in such cases, the question is not whether the defendant acted with due care, but whether their acts occasioned the damage. This is a key feature of strict liability.
• The court reasoned that when one person, in managing their own affairs, causes damage to another, even innocently, it is just that they should be the party to suffer the consequences.
• This case established a form of strict liability for certain activities that are deemed to be especially dangerous or inappropriate for the area in which they occur, setting a precedent in tort law that continues to be influential.

Conclusion

• Hence, it was held that the respondent is liable to pay the losses incurred by the plaintiff.