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Rylands v fletcher case summary

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Rylands v fletcher case summary

Rylands v. Fletcher is a famous English case that established the ‘Rule of Strict Liability’.

The principle used here is “Strict liability”.

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Rylands v fletcher case summary

Facts :

In this case, Mr. Fletcher was leasing a coal mine, and his neighbor, Mr. Ryland, owned a mill and wanted to build a water reservoir on his property. To get this done, Mr. Ryland hired an independent contractor.

While the contractor was working on the reservoir, the crew noticed some hollow areas. Instead of fixing those properly, they filled them with mud and continued building. After the reservoir was completed and filled with water, it started leaking from these spots, which caused a lot of damage to Mr. Fletcher’s coal mine.

As a result, Mr. Fletcher decided to file a lawsuit, seeking compensation for the losses he incurred due to what he believed was negligence on Mr. Ryland’s part.

Issue :

Whether the defendants can be held liable or was there any nuisance ?
If the defendants are liable, then for which negligence they could be punished ?

Judgement :

The House of Lords dismissed Ryland’s appeal. The house of Lord’s gave the judgement that they are being held liable for the negligence of the tort. The defendants were held liable under the doctrine of strict liability.

The doctrine of Strict liability :-

The doctrine of strict liability was laid down in this case only :-

1.The wrong material should be present.

To make the rule from Ryland v. Fletcher work, the first thing we need is a dangerous item. A person can be held responsible only if what they’ve collected or brought in is considered dangerous. What counts as dangerous can change depending on the situation. Some examples of these risky items include poisonous plants, explosives, harmful fumes, and rusty wires. It’s all about understanding the potential for harm in each case!

2.The wrong material should be escaped :

For the strict liability rule to apply, a crucial requirement is that the dangerous item must escape the defendant’s control. Specifically, “the thing must escape to an area outside the occupation and control of the defendant.” If the item stays within the defendant’s premises and causes damage, they cannot be held liable. For example, consider a scenario where you purchase explosives for an experiment at home. If the explosives accidentally detonate while you’re conducting the experiment and injure a co-worker, you wouldn’t be liable under strict liability. This is because the explosive material did not escape beyond your property boundaries.

3.Non natural use of land:

The last piece of the puzzle for understanding the rule of strict liability is that the dangerous thing has to come from a non-natural use of land. To be considered non-natural, the use should involve a special situation that brings extra risks to others, rather than just the usual way land is used for everyone’s benefit. For example, growing a regular tree is perfectly normal and safe, but if you decide to plant a poisonous tree, that’s a different story! It creates an added danger, making it a non-natural use of land.

Exceptions to the Rule of Strict liability :

Plaintiff’s Own Fault :

When it comes to damages, if a plaintiff is at fault for what happens, the defendant typically isn’t responsible for any compensation related to losses on their land. A great example is the case of *Ponting v. Noakes*. In this situation, the plaintiff’s horse wandered onto the defendant’s property and ended up eating some leaves from a Yew tree, which unfortunately led to the horse’s death. The court decided in favor of the defendant, explaining that the plants on their land hadn’t spread onto the plaintiff’s side. Instead, it was really the horse that trespassed and caused the issue. Since the plaintiff was responsible for the incident, he couldn’t claim any compensation for the loss.

Act of God :

When the loss suffered by the plaintiff results from natural forces that are so unpredictable that they cannot be anticipated, the plaintiff is generally not entitled to any remedy or compensation. This principle is illustrated in the case of Nicholas v. Marsland. In this case, the defendant had constructed an artificial lake on his property, which overflowed due to heavy rainfall, causing significant damage to the plaintiff’s home. The plaintiff sought compensation for the damages, but the court ruled that the harm resulted from unexpected natural forces. Since no negligence was identified on the defendant’s part, he was not held liable for the plaintiff’s losses.

Act of third party:

When damages result from the actions of a third party or stranger over whom the defendant has no control, the principle of strict liability cannot be applied. A compelling example is found in Box v. Jubb, where individuals obstructed the drain of the defendant’s reservoir, ultimately causing it to overflow and damage the plaintiff’s property. The Court ruled that the defendant was not liable, as the harm was solely due to the actions of an unrelated party. This case illustrates the necessity of establishing control for liability to arise.

Statutory Authority:

When a person suffers damage because of an act done under legal authority, it raises questions about responsibility. Generally, people acting within the law are protected. However, if the act was careless or if someone went beyond their legal rights, exceptions may apply. It’s important to look at the specific situation and laws involved to assess any claim

Volenti Non-Fit Injuria(consent)

When a claimant has either impliedly or expressly agreed with the defendant to share in the risks of a harmful situation, the defendant typically isn’t liable for any resulting harm, unless the claimant can demonstrate that the defendant acted with a lack of due care or negligence. A relevant example is the case of Dunne v. North West Gas Board, where the plaintiffs filed a lawsuit against the Gas Board after a gas leak from a ruptured water main resulted in five casualties. In this instance, the court ruled that the Gas Board was not liable, as the situation was considered a consented act, and the Gas Board had not retained the gas for its own advantage.