Ratio Decidendi
A person who brings onto their land and collects and keeps there anything likely to do mischief if it escapes must keep it in at their peril, and if they fail to do so, they are prima facie answerable for all the damage which is the natural consequence of its escape. This is a form of strict liability for non-natural use of land.
Ffeithiau
Rylands employed contractors to construct a reservoir on his land. The contractors discovered old mine shafts during construction but failed to seal them properly. When the reservoir was filled, water burst through the old shafts and flooded Fletcher's adjoining coal mine. Rylands was not personally negligent — the fault lay with the independent contractors.
Crynodeb o'r dyfarniad
The House of Lords affirmed the decision of the Court of Exchequer Chamber (where Blackburn J had formulated the rule). Lord Cairns LC added the requirement that the use of land must be 'non-natural'. The rule imposes strict liability: the defendant need not have been negligent. The essential elements are: (1) the defendant brought something onto their land, (2) it was a non-natural use of the land, (3) the thing was likely to cause mischief if it escaped, and (4) it did escape and cause damage.
Dyfyniadau allweddol
"The person who for his own purposes brings on his lands and collects and keeps there anything likely to do mischief if it escapes, must keep it in at his peril, and, if he does not do so, is prima facie answerable for all the damage which is the natural consequence of its escape."
— Blackburn J (Court of Exchequer Chamber)
Triniaeth ddilynol
Followed as the basis for strict liability for escape of dangerous things from land.
The scope has been significantly restricted by Cambridge Water Co v Eastern Counties Leather [1994], which added a requirement of foreseeability of damage, and Transco plc v Stockport MBC [2003], which confirmed it as a sub-species of nuisance rather than a general principle of strict liability.