Case name: Rylands v. Fletcher
Year of decision: 1868
Court: House of Lords
Case citation: Rylands v. Fletcher, 3 H.L. 330 (1868)
Rylands, hereinafter referred to as the Defendant, owned a piece of property, which did not qualify for rights to mines and veins coal beneath the surface. Fletcher, hereinafter referred to as the Plaintiff, Had in his possession coalmines that lay adjacent to the Defendant’s property.
The Defendant caused the construction of a reservoir on his piece of property. The reservoir lay slightly above an abandoned coalmine, which happened to be connected the Plaintiff’s mines in the surface below.
The construction of the artificial pond by the Defendant eventually led to the collapse of the mineshaft. The collapse caused floods, a case that frustrated and/or negated the possibility of the Plaintiff to undertake the operation of the mines.
The Plaintiff sued for damages. The matter was brought before an arbitrator who for purposes of establishing the facts. The trial court found for the Plaintiff. Dissatisfied with the decision, the Defendant appealed. Consequently, the Appellate court affirmed the judgement.
The Defendant appealed again, to the House of Lords, which upheld the decision.
Legal Issues in Rylands v Fletcher
- Is an absolute duty imposed on a landowner who accumulates, acquires and brings a thing onto his land and whereby the thing remains on the land in its harmless state with the possibility of eventually and naturally causing damage on escaping?
- Will a party in a suit be liable for damages emanating from actions of a thing whereby such actions are unduly dangerous and inappropriate in a given environment with regard to the character of such an environment?
Law in Rylands v Fletcher
For a party to assert breach of duty, such a duty must be proven to exist in first case. Lord Cracnworth alluded to the decision that was arrived at in Smith v. Kenrick thereby stating that the Plaintiff has to prove on balance of probabilities that he was owed a duty of care. Breach follows the duty.
The Court borrowed from the decision in Lambert v. Bessey, as was reported by Thomas Raymond, to state that the Plaintiff bears the onus of justifying that the Defendant acted in manner that is unreasonable and thus breached the duty of care.
The breach of duty of care must cause the Plaintiff to suffer harm, which is not too remote (Baird v. Williamson, 1863).
Analysis in Rylands v Fletcher
Holding and Rule 1: In the first legal issue, the Court found in the affirmative. It stated that the law imposes an absolute duty on a landowner and/or a person who lawfully acquires, accumulates and brings something onto his land, which though harmless while it remains on the land, will naturally cause harm if it escapes.
The impact of this rule is that Defendants are prima facie liable for all the damage that accrue as a result of the thing’s escape. The Plaintiff therefore is under no obligation of establishing or showing that the Defendant’s conduct is negligent. However, the Defendant can assert the defense that the thing’s escape was the Plaintiff’s fault or that the damage occurred because of a major act of God.
Holding and Rule 2: The Court found in the affirmative. It stated that where a landowner, without negligence or willfulness, appropriates his property in the ordinary sense of its use, he will not be liable for damages should mischief be occasioned to his neighbor.
However the Court cautioned that if the landowner brings upon his property a thing which is in itself dangerous and would not naturally come upon such property and may cause mischief if not controlled properly, in as much as he will be acting without negligence or personal willfulness, he will be liable for any damages occasioned by the thing’s mischief.
Conclusion in Rylands v Fletcher
The Defendant was found liable for damages that were occasioned by the floods.