Rylands v. Fletcher
Citation: L.R. 3 H.L. 330 (1868)
Facts
Fletcher had contractors build a reservoir on his land. The contractors negligently failed to seal old mine shafts. When the reservoir was filled, water burst through the shafts and flooded Rylands’s adjacent coal mines.
Issue
Is a landowner strictly liable for harm caused by water escaping from a reservoir on his land, even if he was not personally negligent?
Holding
Yes. A person who brings onto his land something likely to do mischief if it escapes must keep it at his peril. If he fails to do so and it escapes and causes damage, he is prima facie answerable for all the damage that is the natural consequence of its escape.
Rule
Rylands v. Fletcher strict liability rule: A person who brings onto his land or collects there anything likely to do mischief if it escapes is strictly liable for all damage that is the natural consequence of its escape, regardless of whether the person was negligent. Exceptions: Act of God, plaintiff’s own fault, and natural use of land.
Natural vs. non-natural use: Liability applies only to non-natural uses of land. Ordinary use of land that does not involve unusual danger is not covered.
Significance
- Created the foundational doctrine of strict liability in English law
- Adopted in a small minority of U.S. jurisdictions; most states limit it or have rejected it
- Restatement (Second) of Torts §§ 519–520 codifies strict liability for abnormally dangerous activities — the U.S. analogue to Rylands
- The “non-natural use” limitation parallels the “abnormally dangerous activity” requirement in American law