Fletcher vs. Rylands
Fletcher vs. Rylands (1868) is a landmark case in tort law. The House of Lords established the rule recognizing 'No Fault' liability in this case. This case gave rise to the 'Rule of Strict Liability.' According to this rule, a person may be liable for some harm even if he is not negligent in causing it. Furthermore, this case paved the way for India's "Rule of Absolute Liability."
Rylands, the defendant, had a reservoir built over his land by independent contractors to supply water to his mill. There were some old disused shafts beneath the reservoir site that the contractors failed to notice. As a result, they did not obstruct the shafts. When the reservoir was filled with water, it burst through the shafts. As a result, the plaintiff's coal mines on adjacent land were flooded. The defendant was unaware of the shafts, and he was not negligent, whereas the independent contractors were. The failure was due to the negligence of independent contractors. Fletcher, the plaintiff, sued the defendants because he had to suffer losses.
Whether or not there was any annoyance?
Was Defendant's use of his land unreasonable, and thus was he liable for the Plaintiff's damages?
The Liverpool Court of Appeal
This court ruled in favour of the plaintiff on the grounds of trespass (because the flooding was not "direct and immediate") and nuisance. Later, a court order resulted in the appointment of an arbitrator from the Exchequer of Pleas in December 1864. The arbitrator ruled that the independent contractors were liable for negligence because, despite knowing about the old mine shafts, they acted negligently in dealing with them. Rylands, according to the arbitrator, had no way of knowing about the mine shafts and thus could not be held liable.
the case was then heard at the Exchequer of Pleas on the 3rd and 5th of May 1865. It was heard on two occasions:
Whether the defendants were liable for the contractors' actions and
Whether the defendants were liable for the damage even if they were not negligent.
They agreed on the first point, that the defendants were not liable, but they disagreed on the second. Channell B recused himself. Pollock CB and Martin B ruled that the defendants were not liable because there was no valid case. After all, a negligence claim could not be brought. Dissenting, Bramwell B argued that the claimant had the right to enjoy his land free of interference from water from the defendant's reservoir and that as a result, the defendant was guilty of both trespasses and commissioning a nuisance. He stated that "the general law, wholly independent of contract," should hold the defendants liable "on the simple ground that the defendants caused water to flow into the [claimant property." ]'s
Fletcher was enraged by the decision of the three exchequer judges and filed an appeal with the exchequer chamber of six judges. "The previous decision was overturned" by the six judges. Fletcher. "We, the judges of the exchequer think that correct rule of law is that any person, who for his intentions brings on his land anything, accumulates and keeps on the land that thing, which is likely to cause trouble if it escapes, must keep it at his own risk, and, if he doesn't do so, is clear (without need for further information), in charge of all the damage which is that the natural effect of its egress."
Blackburn J went on to say that "that person can excuse himself from liability by claiming that the escape was caused by the plaintiff's default; or by proving that the escape was a result of an act of God."
The judges concluded that "none of these excuses had been proven in the case," making it "unnecessary to determine what other excuse would suffice." The judges relied on the "basis of the liability for damages of land through the tort of chattel of trespass, the tort of nuisance," as well as "the scienter action (common law rule that deals with the damages directly done by animals to human beings)" in their decision.
Rylands was found liable for the damage done to the Fletcher by the Exchequer Chamber. The court determined that the defendants owed a duty of care to the risk because they were aware that if that amount of water escaped, it would be harmful. The defendants showed a lack of concern by storing such a large amount of water on their property, which was an unnatural use of their land. Though it was not harmful at the time, it would be dangerous if it escaped.
Rylands thought this was unjust. He appealed to the House of Lords.
House Of Lords
The House of Lords dismissed Ryland’s appeal. They agreed with the six exchequer judges but went further to feature a limitation on the liability.
The appeal was dismissed by the House of Lords, who agreed with the six Exchequer judges. While speaking for the House of Lords, Lord Cairns stated that the House of Lords agreed with the rule stated above by Justice Blackburn in the Exchequer Chamber, but added a further limitation on liability. Another requirement is that the land from which the escape occurs be altered in a way that is considered non-natural, unusual, or inappropriate. The House of Lords' decision added a requirement that the use is 'unnatural.' The decision, in this case, was handed down on July 17th. The court was made up of only two judges, Lord Cairns and Lord Cranworth; Lord Colonsay did not attend.
Ryland vs. Fletcher was a significant case in determining an owner's liability when bringing a dangerous object onto his property. It was necessary to have a law that could increase the owner's duty. So that he can be more cautious when bringing any potentially dangerous objects into his premises. The world is changing at a breakneck pace, and in this era of industrialization, privatization, and globalization, disputes over the duty of care are exploding, necessitating the creation of a law to address these issues. In this case, this was done. This Rule of Strict Liability paved the way for 'The Rule of Absolute Liability in India.