A case summary of Rylands v Fletcher
Case name: Rylands v Fletcher (1868) LR 3 HL 330
This case is one of the most famous cases in English common law. It revolves around the principles of liability under tort law.
Facts of the case: Rylands v Fletcher
In the case of Rylands v Fletcher (1868) LR 3 HL 330, the defendant went on to build a reservoir on his land to increase the water supply there, but the water from the reservoir flowed down to the coal mine in the neighbourhood, which belonged to the plaintiff. Thus, it caused damage.
The reservoir was built by some engineers who had been hired by the defendant as independent contractors. Even though the defendant had not been negligent as he had hired competent engineers to do the job, he was accountable for the loss caused by the operations carried out on his land.
Hence, at the Court of the Exchequer, the defendant was held liable without having been negligent.
The Court was of the view that the question of negligence was quite unimportant. When the defendant brought water into the reservoir, he was bound to keep it there at his own risk, and was hence, liable.
What did the Judge come up with?
In the instant case of Rylands v Fletcher, Justice Blackburn came up with a new method where he sought whether he could provide relief to the victims of a non-negligent accident arising from a set of dangerous circumstances. He found out that even if there may be no fault or negligence on the part of the person whose actions led to that inherently dangerous act, he may still be held liable for damages caused due to such act.
Thus, it can be deduced that:
- Liability will be imposed
- Even if the party has not been negligent
Evolution of the principle of strict liability in Rylands v Fletcher’s case
This case first established the principle of strict liability.
It lays down the following:
“Anyone who in the course of “non-natural” use of his land “accumulates” thereon for his own purposes anything likely to do mischief if it escapes, is answerable for all direct damage thereby caused.”
This gave rise to a fresh understanding of tortious liability. If a non-negligent accident has occurred while a person is making a non-natural use of land and the non-natural thing escapes and causes mischief, he will be held liable for damages. This principle is also called the principle of no-fault liability.
Therefore, to constitute a strict liability, the following essential elements must be present:
- There has to be some hazardous thing that is brought by the defendant onto his land.
- The hazardous thing must have escaped the territory of the defendant and must have caused damage.
- There has to be a non-natural use of land.
Let us see these elements in a little detail.
Firstly, it should be understood that considerations of time, place, surroundings, circumstances, and purpose all contribute to deciding whether a certain use is natural or non-natural. For instance, a person keeping wild animals on his land is an example of non-natural use of land, as is a person creating a reservoir on his land to harness water.
Further, the hazardous thing that constitutes non-natural use of the defendant’s land must escape from his premises and must lead to some damage or legal injury to the plaintiff.
If these conditions are present, the rule of strict liability comes into play and the plaintiff can be compensated.
Exceptions to the rule of strict liability
As stated earlier, the rule of strict liability applies only in the case of non-natural usage of land. It shall not be applicable to things naturally present on land or where the escape is because of an act of God, an act of a stranger, the plaintiff’s own consent, or due to the default of the person who has been injured.
As far as Indian Law is concerned, it has been held in many instances that the rule of Rylands v Fletcher applies in India.
In nutshell, the rule of Rylands v Fletcher states that a person who collects and stores on his land for his own purposes anything prone to cause mischief shall be accountable for it at his own risk if it escapes. If he fails to do so, he is liable for the damage that is the natural consequence of its escape. The obligations under this rule are stringent, and no defense that the thing escaped without that person’s will, default, or omission is allowed. Hence, he must make amends for the harm he has caused.
This rule has wide applicability and also set the route for the establishment of another similar but more stringent rule called “Absolute Liability”.
To read more about the rules of Strict Liability and Absolute Liability, please refer to this blog:
Strict Liability and Absolute Liability: A detailed guide!
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