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Rylands v. Fletcher

Citation. Court of Exchequer, 3 H. & C. 774, 159 Eng. Rep. 737 (1865); Exchequer Chamber, L.R. 1 Ex. 265 (1866); House of Lords, L.R. 3 H.L. 330 (1868)
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Brief Fact Summary.

The coal mine of Fletcher (Plaintiff) was flooded when Rylands (Defendant) built a reservoir on his neighboring land.

Synopsis of Rule of Law.

A defendant is strictly liable for harm done by any escaping, non-natural thing that he brought onto his land.

Facts.

Rylands (Defendant) had a reservoir built on his land, which contained old mining tunnels. The tunnels connected to Fletcher’s (Plaintiff) coal mine. When the reservoir was filled with water, it flooded and damaged Plaintiff’s mine.

Issue.

Is Defendant strictly liable for the harm caused by flooding?

Held.

Yes, the Court held Defendant is strictly liable for the harm caused by flooding. The Court reversed the decision by the Court of Exchequer.

Discussion.

Defendant had brought something (water) onto his land that, while harmless if it stayed put, could cause harm if it escaped. Defendant should have taken care to make sure it did not escape. Anyone who brings something onto their land that is likely to do harm if it escapes is strictly liable for any damage caused if it does escape because he has an absolute duty to keep it within his land.


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