Rylands v. Fletcher

Citation. L.R. 3 H.L. 330 (House of Lords, 1868)

Brief Fact Summary.

Rylands owned a reservoir that sat on top of abandoned mining shafts that were filled with subsoil. Water from the reservoir burst into the shafts and travelled to mines used by Fletcher, flooding them.

Synopsis of Rule of Law.

A person who for his own purposes brings anything onto his land that is likely to do damage if it escapes is prima facie liable for all damages that are a natural consequence of its escape.

Facts.

A reservoir owned by Rylands broke into ancient mining shafts below it that were connected to mines used by Fletcher, causing Fletcher’s mines to flood. When building the reservoir, Rylands’ engineers discovered these abandoned mining shafts that were filled with subsoil beneath the reservoir, but they did not inspect where these shafts went. Rylands operated in total ignorance of the latent defect found in the subsoil that allowed the flooding to occur.

Issue.

May Fletcher recover any damages from Rylands?

Held.

Affirmed.

Yes, Fletcher may recover damages from Rylands.

Discussion.

If Rylands had on the surface or underground of his land by natural circumstance an accumulation of water and that water passed off into Fletcher’s mine, Fletcher could not recover any damages because Rylands was enjoying the natural use of his land in the ordinary course.

However, if Rylands configured his land into a non-natural use (i.e., the reservoir) and that configuration resulted in the flooding of Fletcher’s mine, then Fletcher may recover damages from Rylands because Rylands created the reservoir at his own peril to be properly maintained regardless of the care that went into constructing the reservoir and regardless of any precautions Rylands took to keep the reservoir safe.