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Rylands v. Fletcher | L.R. 3 H.L. 330 (1868)

Tort law typically requires a defendant to have acted negligently before an injured plaintiff can recover damages. If a defendant hasn’t been negligent, the injured plaintiff usually can’t win. But for certain types of danger, the law has developed the principle of strict liability. Under this doctrine, certain harmful acts can merit compensation, even if the defendant didn’t act negligently. The British case of Rylands versus Fletcher considers one situation in which strict liability applied.

In 1860, Rylands owned a mill in Lancaster County, England. They wanted to build a reservoir to supply the mill with running water, so they hired an engineer and other contractors. The engineer then selected the reservoir’s location, designed it, and built it.

But long before the reservoir went up, the site had been mined for coal. Decades, perhaps centuries earlier, five vertical shafts had been dug, then later filled with soil, rocks, and timber. By the time Rylands came along, these ancient shafts were completely hidden and long forgotten. Rylands’s engineer discovered the shafts during the reservoir’s construction, but didn’t warn Rylands about them. They completed the reservoir and began to fill it with water.

Fletcher operated coal mines on land adjacent to Rylands’s mill and reservoir. Fletcher’s mines connected to various underground caves and crevasses, and eventually, to the ancient shafts now underneath Rylands’s reservoir.

In December, as the reservoir was being filled, one of the ancient shafts collapsed. Water flooded down and throughout the subterranean structure, and into Fletcher’s coal mines. Fletcher was forced to suspend mining, and eventually, he abandoned his entire mining operation.

Fletcher sued Rylands for losses stemming from the mine’s closure. A jury trial found for Fletcher.

On appeal, the Court of the Exchequer reversed the trial court, ruling that Rylands, having no knowledge of the mineshafts or their connection to Fletcher’s mines, wasn’t negligent. Therefore, Rylands couldn’t be held liable for Fletcher’s losses. That decision was reversed by the Exchequer Chamber, which ruled that because Rylands collected a dangerous quantity of water in his reservoir, he was liable for Fletcher’s damages.

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