Quick Summary
Fletcher (plaintiff) and Rylands (defendant) were neighboring landowners with Fletcher’s coal mines suffering damage due to a breach in Rylands’ reservoir.
The issue presented was whether a person is strictly liable for damage caused by substances they bring onto their land that escape and cause mischief. The Exchequer Chamber concluded that Rylands was indeed liable as he failed to contain the water, which was not naturally present on his land and knew to be harmful if it escaped.
Facts of the Case
Fletcher (plaintiff) operated coal mines adjacent to land where Rylands (defendant) constructed a reservoir to supply water to his mill. Rylands, unaware of the abandoned mines beneath, employed engineers and contractors for the construction.
Post-completion, the reservoir broke and flooded Fletcher’s mines, causing significant damage. Fletcher sued Rylands for the damages caused to his property.
Procedural Posture and History
- The Court of Exchequer initially found Rylands not liable for the damage caused to Fletcher’s property.
- Fletcher appealed the decision to the Exchequer Chamber.
I.R.A.C. Format
Issue
Whether the person who brings onto their land a substance likely to cause mischief. if escapes – is strictly liable for any damage caused as a result of its escape.
Rule of Law
The person who, for their own purposes, brings and keeps on their land anything likely to cause damage if it escapes, is strictly liable for all damage which is the natural consequence of its escape.
Reasoning and Analysis
The court reasoned that the duty imposed upon a person who brings potentially dangerous substances onto their property is absolute. This person must ensure these substances do not escape and cause damage to others. The law requires such individuals to keep these substances contained at their own peril.
In this case, since Rylands brought water onto his land, which was not naturally there and knew it to be potentially harmful if it escaped, he should be responsible for any ensuing damage.
The court distinguished this from cases of inevitable risk, such as traffic accidents, where individuals assume some level of risk by being near highways. In contrast, Fletcher did not assume any risk related to the use of Rylands’ land; therefore, Rylands is held liable for the damages caused by the escape of water from his reservoir.
Conclusion
The Exchequer Chamber reversed the decision of the Court of Exchequer, holding Rylands liable for the damages caused by the escaped water from his reservoir.
Key Takeaways
- A person who brings a potentially dangerous substance onto their land has an absolute duty to prevent it from escaping and causing damage.
- Strict liability applies even if there is no negligence or intent to harm on the part of the landowner who brought the substance onto their property.
- The case establishes a precedent for what is known as ‘Rylands v. Fletcher rule’, which is a form of strict liability applied in certain circumstances of non-natural use of land.
Relevant FAQs of this case
What constitutes a 'non-natural' use of land in terms of imposing strict liability?
‘Non-natural’ use of land refers to any activity that increases the risk of harm to others beyond what would be expected from the ordinary use of the land, thereby triggering strict liability for any resultant damage. Such use often involves the storage or accumulation of substances that do not exist there naturally and which could pose hazards if they escape.
- For example: Storing large volumes of chemicals in a residential area would be considered ‘non-natural’ use, as it significantly heightens the risk to neighboring properties beyond typical residential activities.
Under what circumstances is a person strictly liable for damage caused by their property?
A person is strictly liable for damages when they engage in activities or keep substances on their property that are inherently dangerous or considered ‘non-natural’ uses of the land, and when these activities or substances lead to damage when they escape, regardless of whether fault or negligence exists.
- For example: If someone keeps a collection of wild, exotic animals on their property and one escapes, causing injury or damage, they would be strictly liable because wild animals are considered an inherently dangerous condition.
How does the concept of 'assumption of risk' interact with strict liability?
The concept of ‘assumption of risk’ suggests that if an individual is aware of and voluntarily accepts a known danger, they might not have grounds to claim damages. However, in strict liability cases like Rylands v. Fletcher, this defense is less applicable as liability isn’t based on negligence but on the mere escape of a hazardous substance.
- For example: Attending a baseball game implies assuming the risk of being hit by a stray ball; however, if injury arises due to a structural failure unrelated to the game’s inherent risks, strict liability may apply without considering ‘assumption of risk.’
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