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Rylands v. Fletcher

House of Lords
L.R. 3 H.L. 330 (1868)

Rylands v. Fletcher

Facts

Fletcher (plaintiff) leased several underground coal mines from land adjacent to that owned by Rylands (defendant). Rylands owned a mill, and built a reservoir on his land for the purpose of supplying water to that mill. Rylands employed engineers and contractors to build the reservoir. In the course of building the reservoir, these employees learned that it was being built on top of abandoned underground coal mines. This fact was unknown by Rylands. After the reservoir was completed, it broke and flooded Fletcher’s coal mines. This caused damage to Fletcher’s property, and Fletcher brought suit against Rylands. Justices in the lower court differed as to whether Rylands should be liable, and the decision was appealed to the Court of Exchequer Chamber. There, Rylands was held strictly liable for damage caused to Fletcher’s property by water from the broken reservoir. Rylands appealed.

Rule of Law

Issue

Holding and Reasoning (Cairns, L.C.)

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