CASE no. 1
Rylands
V.
Fletcher
Rylands v. Fletcher, (1868) LR 3 HL 330 (HL).
Landmark Case on Strict Liability in Tort Law
Author- Anamika Rao, First year B.A.LLB(Hons), C.M.P. Degree College, University of Allahabad, Prayagraj
ABSTRACT
One most
important ruling in the common law tradition, especially in the area of tort
law, the case is Rylands v. Fletcher (1868). It established the ‘Rule of Strict
Liability’ doctrine, which states that anyone who brings and keeps anything
that could cause trouble if it escapes must do so at their own risk. According
to this rule, “ A person is legally accountable for the loss caused to the
plaintiff even if the dependent was not negligent or rather, even if the
defendant wascareful, he did not have evil intention to cause harm,he could
still be liable under the rule. This rule is sometimes referred to as ‘no
fault’ liability.
PRIMARY DETAILS OF THE CASE
|
Case no: |
Court of
Exchequer Chamber Civil Appeal |
|
Jurisdiction: |
United Kingdom
House of Lords |
|
Case Filled on: |
4th November,
1861 |
|
Case Decided on: |
17th July, 1868 |
|
Judges: |
Lord Cairns, LC
Lord Cranworth |
|
Legal provision
involved: |
Rule of Strict
Liability |
|
Case Summary
prepared by: |
Anamika Rao |
BRIEF
FACTS ABOUT THE CASE
To store
water for his mill, Thomas Fletcher built a reservoir on his land. To complete
the project, he hired independent contractors. Regretfully, neither he nor his
engineers were aware that the building site was situated atop old, deserted
mine shafts that led to nearby Ryland’s property, where a coal mine was still
in operation. These shafts allowed water to escape when the reservoir was
filled, flooding Rylands’ mine and seriously damaging it. Rylands filed a
lawsuit to get compensation, claiming that Fletcher ought to be held
accountable for the harm. Fletcher asserted that he was unaware of the hidden
shafts, had acted in good faith, and had adhered to the correct processes. The
case made its way to the House of Lords after passing through lower courts.
ISSUES
INVOLVED IN THE CASE
1.
Liability
without negligence:
Even if
someone was not at fault or negligent, could they still be held
Legally liable for damages brought on by an
escape from their property? This case raised the question of whether an act’s
consequences, independent of its intent or level of care, could give rise to
tort liability. Which is meant by “non-natural use” of land and building and
maintaining a sizable reservoir qualify as an “extraordinary” or “non-natural”
use of land, subject to strict liability or a higher duty of care. The
distinction between normal and abnormal land use had to be made by the court.
2.Even
though the defendant was unaware of the underground mine shafts, he should
takecare of This brought up the question of whether responsibility was absolved
when one was unaware of hidden dangers.
3.Accountability
for independentContractors’ actions:
Fletcher’s
hiring of qualified contractors absolve him of responsibility. The court
considered whether hiring third parties to complete the task absolved or
transferred legal responsibility.
ARGUMENTS OF THE PARTIES
PLAINTIFF:
1.
The
Direct causation of damage:
According
to the plaintiff, the building and filling of the reservoir on Fletcher’s
property was the direct cause of the flooding of his coal mine.
2.
Nature
of work is Hazardous:
Keeping
a lot of water in a reservoir was risky, particularly because of the
subterranean structures. Consequently, the defendant ought to be held
accountable for participating in a risky activity.
3.
Negligence
:
According
to the plaintiff, negligence did not need to be demonstrated. According to
strict principles, liability was established because the harm was caused by a
dangerous substance escaping.
4.
Non-natural
use of land:
In the case of Hodgkinson v. Ennor, the
defendant polluted a stream by activities on his own land which is a
non-natural use of land and made him liable for damages.
In that
particular context, the reservoir constituted an extraordinary risk and was not
a natural use of land. Therefore, the defendant ought to bear full
responsibility for any escape and any harm that results.
5.
Duty
of care :
According
to the plaintiff, anyone who brings potentially dangerous materials onto their
property must make sure that no one else is harmed.
6.Personal
liability cannot be transferred:
It was
stated in the principle of ‘Qui facit per alium facit per se‘ principle that
the defendant is liable for the negligence of his agent i.e. the contractor.
DEFENDANT:
1.
Absence
of negligence:
Fletcher
defend himself by arguing that he had built the reservoir by a competent
contractor with every possible precaution. He maintained that since he acted
responsibly and in good faith, there was no negligence on his part.
2.
Hiring
of contractors:
Qualified
and experienced independent contractors were given the task. Fletcher claimed
that since he had assigned the task correctly, he should not be held
accountable for any mistakes they made.
3.
Unaware
of underground mine shafts:
In the
case of Chadwick v. Trower, clearly distinguished that, the defendant is not
accountable for damage and not liable for damages which was due to an unknown
wall of the neighborhood build underground. As in this case defendant (
Fletcher)stated that he had no idea that there were abandoned mine shafts
beneath the building site. He and the contractors were unaware of the existence
of these shafts, so the damage that resulted was unexpected. No evil intent or
intentional act to cause harm was stressed by Fletcher. An otherwise beneficial
and legal activity resulted in the flooding by accident.
4. Natural
use of land:
He
believed that building a reservoir to supply water to his mill was a normal and
reasonable industrial use of land rather than something unusual or
“non-natural.”
4.
Unexpected
escape:
Fletcher
felt that strict liability should not be applied because the escape happened as
a result of latent, hidden geological conditions rather than any fault of
construction or operation.
LEGAL
ASPECTS INVOLVED
The
concept of strict liability for dangerous activities carried out on one’s
property was established by the Rylands v. Fletcher ruling. The House of Lords
claims that “the person who, for his own purposes and use, brings on his lands
and collects and keeps there anything likely to cause trouble for other, if it
escapes must keep it in at his peril, and if he does not do so, the person who brings
liable for any damage ,he is first answerable person to,that is the natural
consequence of its escape.”
1.
Something must have been brought onto the defendant’s property.
2. The
land must be used in a non-natural way.
3. The
material must have the potential to cause trouble if it escapes.
4. The
defendant’s land must be accessible. The harm needs to be predictable.
JUDGEMENT
The Exchequer
Chamber’s ruling was upheld by the House of Lords in Rylands v. Fletcher
(1868), solidifying the strict liability doctrine in English tort law. Whether
a person could be held accountable for a hazardous material escaping from their
property and causing harm to another person’s property was the main question,
not negligence. In his leading opinion, Lord Cairns LC said, “The individual
who brings anything that could cause trouble if it escapes onto his property
for personal gain must do so at his own risk.” This meant that regardless of
whether they took reasonable precautions, someone is responsible if they bring
something dangerous onto their property and it escapes and causes damage.
Large-scale water storage in a reservoir was deemed by the court to be a
“non-natural use” of land. This set it apart from commonplace applications like
home construction and agricultural cultivation. Fletcher was responsible when
the risk materialized because his use of the land created a novel and
exceptional risk. Then, Fletcher’s argument that he had hired qualified engineer
and contractor and he was ignorant of the old mine shafts was dismissed by the
court . It was up to him to keep the risk under control. This decision
established the foundation for industrial and environmental liability, holding
companies and landowners accountable for actions that may cause harm to others
even when there is no fault. The ruling, which prioritizes responsibility over
intent, is still a pillar of tort law. Abandoned mine shafts led to Rylands’s
nearby property, where a coal mine was still in operation. After the reservoir
was filled, Rylands’ coal mine was severely damaged when water seeped out
through the abandoned shafts. Rylands filed a damages lawsuit against Fletcher.
Fletcher argued that he was unaware of the mine shafts beneath the surface and
had not been careless. After the proceedings of the case in English court the
House of Lords declared the decision.
IMPACT
AND SIGNIFICANCE
Strict
Liability’s Development Doctrine: The decision established strict liability as
a separate tort that does not call for evidence of negligence.
Impact on Environmental Law:
The case
established fundamental ideas that were subsequently incorporated into
legislative frameworks such as the UK’s Environmental Protection Act of 1990.
Indian
Jurisprudence:
In M.C.
Mehta v. Union of India, (1987) 1 SCC 395, the Indian Supreme Court made
changes and added the idea of strict liability , creating the new rule of
“absolute liability,” eliminating the Rylands doctrine’s exceptions, which
covers possibility of mischief done by anything
which is Non-natural.
CONCLUSION
Rylands
v. Fletcher is a case in whichadded new rule in tort law. It gave rise to the
concept of strict liability, which holds that there are situations in which
responsibility exists irrespective of fault. Even though statutory
interventions have outperformed it in many jurisdictions and judicial
interpretation has restricted its application, its theoretical framework
remains a significant point of reference in both academic and practical
discussions. Risk allocation and accountability, two concepts that are crucial
in modern industrial and environmental contexts, are heavily emphasized in the
regulation.
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