Rylands v. Fletcher – Case Brief

Rylands v. Fletcher, House of Lords, L.R. 3 H.L. 330 (1868).

Case Summary

Facts: See Fletcher v. Rylands

Issue 1: Is an absolute duty imposed on a landowner who lawfully brings something onto his land which, while harmless while it remains there, will naturally cause damage if it escapes?

Issue 2: Will a party be liable for damage caused by a thing or activity that is unduly dangerous and inappropriate in a certain place, in light of the character of the place and its surroundings?

Holding and Rule 1: Yes.

The law casts an absolute duty on a person who lawfully brings on his land something which though harmless while it remains there will naturally cause damage if it escapes. Ds are prima facie answerable for all the damage which is the natural consequence of its escape. The plaintiff does not have to show negligence. The defendant however can use as a defense a showing that the escape was P’s fault or that it was caused by a major act of God.

Holding and Rule 2: Yes.

Where the owner of land, without willfulness or negligence, uses his land in the ordinary manner of its use, though mischief should thereby be occasioned to his neighbor, he will not be liable in damages. But if he brings upon his land any thing which would not naturally come upon it, and which is in itself dangerous, and may become mischievous if not kept under proper control, though in so doing he may act without personal willfulness or negligence, he will be liable in damages for any mischief thereby occasioned.

Disposition: Reversed, judgment for P.

Notes: This result here is frequently referred to as the “escaping substances doctrine”. This case is the foundation of the concept of strict liability or absolute liability.

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