Overview:
In this case, the House of Lords recognized the Rylands v. Fletcher rule, a general law principle of strict liability for damages arise by escape of dangerous substances brought onto one's land. The person who causes damage to other person either doing the act intentionally or negligently will be held liable to pay damages to the plaintiff.
However, this rule of strictly liability leads to many problems. For example, if I store some explosive material in my premise to do some experiment and it explodes without my negligence or knowledge on its own.
The question arise - Can I be held liable? absolutely not, because there was absence of intention to cause any harm as well as there was no negligence. This rule was propounded by the House of Lords in Rylands v/s Fletcher case to absurd the problem of liability. It is also known as "Rule of Strict liability". According to this, defendant could be liable even there is no negligence on his part.
- Case Name: Rylands v/s Fletcher
- Citation: UKHL 1, L.R. 3 H.L. 330.
- Judges: Lord Cairns and Lord Cranworth
- Date of Judgement- July 17, 1868
Facts of the Case
Rylands (defendant) constructed a reservoir on his land for restoring the water and providing to his mill through an independent contractor. There were few old disused shafts under the reservoir which he failed to fix.
Accordingly, those shafts remained unblocked. When the reservoir filled with the water, there is a burst through the defected shafts and it flooded the coal mines of the plaintiff. Despite the fact, there was no negligence on the part of the defendant, the plaintiff (Fletcher) sued Rylands for compensation.
Issues:
Whether there was any nuisance or not?
Was the use of Defendant's land unreasonable?
Essentials of Strict Liability
Along with Rylands v. Fletcher case, many other various case are helpful to developments regarding the rule of strict liability. Apart from this liability there are several exceptions are also there. For example - Act done by third party and Statutory authority were included in this rule. The essentials for the application of this rule are discussed below:
1. Dangerous Substance:
The first crucial rule is the presence of a dangerous thing or substance. A person can be held liable, if the thing which he had stored was dangerous.
The dangerousness may vary on facts and circumstances of the case. There are several examples of dangerous things - poisonous trees, rusty wire, explosives, noxious fumes etc.
2. Unnatural Use of the Land:
It is also of the required thing for applicability of strict liability. Non natural use of land define as "some special use bringing with it increased danger to others". It must not solely by ordinary use of land or general usage of the property.
For example - if you grow a poisonous tree at your premises that it will considered as unnatural use of the land. Accordingly, If anyone cause damage by that tree then, he will be liable for damages.
3. Escape:
The last requirement for arise this liability is escaping the things. The substance must be dangerous and escape from the property of the defendant. It is essential to escape the dangerous thing, if not escape and damage is still caused the defendant can not be held liable.
For example, if any person brought an explosive material at home. While doing some experiment with these explosives. The material suddenly exploded and injured an employee who working with him. Here, the defendant will be not held liable under the rule of strict liability because there is no escape of the substance outside your premises.
Cases in favour of defendant
1. Smith v. Kenrick:
The plaintiff and defendant adopted mine on the adjacent land. The defendant dug holes in the ordinary mining process as a result of which, the water go out from the holes and then went into the plaintiff's mine as a result, triggered damage.
It was held by the court that the defendant was not liable because each person had a right to work in his own mine in the best method for his benefit. If he did so without any negligence, he was not liable to others for prejudice to his property which might thereby arise.
2. Partridge v. Seott:
In this case, the defendant implemented some skillful persons to perform a lawful act. But some damage to the plaintiff owing to the negligence of the implemented ones. It was held that the population who essentially had done the work alone were liable.
3. Chadwick v. Trover:
In this case, a person pulled down his own wall without giving a notice to his neighbour. Even the defendant was not legally bound to do so and thus damage caused.
Defendant had no knowledge about this wall to causing harm. It was held that the man was not liable as there was no knowledge present on his part that by doing that act.
Conclusion
Landmark case of Rylands V Fletcher which pioneer the term strict liability in law of torts. The rule came into existence for solving the disputes where the harm is caused without any negligence. In this era of industrialization and technology. It is important to make the owner liable, who use of dangerous things and that things caused damage to another person.
This liability has an objective to make owner responsible for its dangerous things. It creates burden on the owner to take the responsibility of all calamity which may be caused by the dangerous thing that he has own.
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