FACTS
In Rylands v. Fletcher, Mr. Fletcher, the plaintiff, operated a coal mine on a leased property near Mr. Rylands’ mill. Rylands intended to build a water reservoir on his land, contracting independent workers for its construction. During the reservoir’s construction, contractors noted hollow areas beneath the site but chose to fill these with mud instead of sealing them adequately. When the reservoir was eventually filled, water leaked through these hollows, causing extensive damage to Fletcher’s coal mine. Fletcher subsequently filed for compensation, citing negligence.
ISSUES
- Was there an act of nuisance?
- Was the defendant’s use of his land unreasonable, warranting liability for the damages caused to Fletcher?
LEGAL PROCEEDINGS
- Court of Liverpool: Initially ruled in favor of the plaintiff based on grounds of trespass and nuisance.
- Exchequer of Pleas: The case was reassessed. The court concluded that Rylands was not liable for the contractors’ actions as there was no evidence of direct negligence. However, Judge Bramwell dissented, holding that Rylands was still responsible for the water escaping his reservoir, which constituted an invasion of Fletcher’s land rights.
- Court of Exchequer Chamber: Overturned the previous ruling, holding Rylands liable. The court developed the strict liability principle, holding that Rylands’ actions posed an inherent risk by accumulating a large volume of water, which posed potential harm if it escaped.
- House of Lords: Ultimately dismissed Rylands’ appeal, concurring with the Exchequer Chamber’s decision. They also added limits to strict liability, acknowledging specific exemptions.
EXCEPTION TO RULE OF STRICT LIABILTY
- Plaintiff’s Own Fault: If the plaintiff’s negligence caused the damage, as in Ponting v. Noakes, the defendant bears no liability.
- Act of God (Vis Major): Unpredictable natural events like severe weather can exempt the defendant from liability, as seen in Nicholas v. Marsland.
- Volenti Non-Fit Injuria: The plaintiff’s informed consent nullifies liability if the risk was voluntarily undertaken. In Peters v. Prince of Wales Theatre Ltd., implied consent to the risk negated defendant liability.
- Act of a Stranger: If a third party causes damage without the defendant’s involvement, as in Rickards v. Lothian, the defendant is not responsible.
- Act of Statutory Authority: When damage results from lawful, government-mandated actions, the defendant is typically exempt from liability, as in Hammersmith Rail Co. v. Brand.
CONCLUSION
Rylands v. Fletcher remains pivotal in establishing the doctrine of strict liability. The decision underscores the responsibility to prevent harm from potentially hazardous actions, regardless of fault, while also clarifying specific defenses that may relieve defendants of liability.
