Rylands vs Fletcher

The well-known Rylands v. Fletcher case established the Rule of Strict Liability. The Rule states that "Even though the individual is not at fault, they are legally responsible for the loss caused to the plaintiff on behalf of the defendant."

This legal theory primarily focuses on the idea that anyone who engages in an activity that causes harm to the plaintiff, whether directly or indirectly, is legally responsible for the plaintiff's injuries on behalf of the defendant, even if that person takes the appropriate safety precautions. This liability exists even in the absence of negligence or malicious intent. The "no" fault liability rule is a common name for this regulation.

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This Story also Contains

1. Rylands v. Fletcher 1866
2. The Rule of Strict Liability
3. The Rule of Absolute Liability
4. Difference between Strict Liability and Absolute Liability
5. Conclusion

Rylands v. Fletcher 1866

Facts of the case

The defendant Rylands hired an independent contractor to create a reservoir across his property so that he could supply water to his mill. The contractors were unaware that there were some old, abandoned shafts beneath the reservoir. As the reservoir filled, water leaked through the shafts and flooded the plaintiff's coal mines on the nearby property. Despite the defendant's lack of responsibility, Rylands, the plaintiff, filed a lawsuit against Fletcher seeking damages.

Issues raised in the case

• Was there any negligence on the part of Rylands

• Should the defendant Rylands be responsible for paying damages to the plaintiff Fletcher and was building a reservoir upon the defendant's property was reasonable

Judgement delivered

Judgement by The Court of Liverpool

The Court of Liverpool ruled in the defendant's favour, concluding that there was no trespassing or nuisance. Later, in December 1864, an arbitrator was appointed by a court order from the Exchequer of Pleas. The arbitrator found that the independent contractors were negligent as they neglected to appropriately handle the abandoned mine shafts even though they were aware of their existence. The arbitrator ruled that Rylands could not be held accountable because he had no way of knowing about the mining shafts.

Judgement by the Court Of Exchequer of Pleas

The Exchequer of Pleas was then notified of the matter. In this case, two questions were answered: first, if the defendants were liable for the contractors' acts; and second, if the defendants were not at fault but still had to pay for the damages.

Although the court reached a majority decision that the defendant was not accountable for the acts of contractors, opinions differed on the second point. Because a negligence claim could not be proved, Pollock CB and Martin B claimed that there was no strong case and that the defendants were therefore not liable. The claimant had the right to enjoy his land free from the defendant's reservoir's water, according to Judge Bramwell B, the dissenting vote. Therefore, the defendant was found guilty of trespassing and commissioning a nuisance. The defendant was found guilty of trespassing and causing a nuisance because the claimant's land was inundated as a result of the defendant's reservoir construction.

Judgement delivered by the Court of Exchequer Chamber

Fletcher filed an appeal with the six-judge Exchequer Chamber after being dissatisfied with the Court of Exchequer of Pleas' ruling. The Court of Exchequer of Pleas' decision was overturned by the judges. This Court was the first to adopt the idea of strict liability.

A guideline for when an owner can become obligated to bring any threat onto his land was set by the Exchequer Chamber court. The court looked into a few defences that might help absolve the defendant of responsibility at the same time.

This led to the establishment of the strict liability rule, which holds people accountable for any damage brought about by a dangerous object they buy for their property, regardless of whether they were careless, aware of the risk, or meant to cause harm. However, the Court also stipulated some exclusions, such as an Act of God or the Plaintiff's default, under which this rule will not be applied. However, since Rylands v. Fletcher lacks any of these exclusions, the court found Ryland accountable for Fletcher's injuries.

Judgement delivered by the House of Lords

Infuriated by the Court of Exchequer Chamber's decision, Rylands filed an appeal with the House of Lords. The House of Lords not only dismissed the appeal but also provided more clarification on the strict liability rule's parameters. The Court determined that for the rule of strict responsibility to be applicable, the land from which escape occurred had to have been transformed in a way that would be considered non-natural, unusual, or improper.

Contentions raised

Mr Ryland asserted that he did not influence the conduct of the indepA judge did, however, rule that Mr Fletcher had the whole right to utilize the land and that Mr Ryland had committed trespass by allowing the water to escape, necessitating the payment of damages. Mr Ryland was declared guilty of trespassing by the court. terminated his contractor hire. For an error made by an independent contractor, he bears no liability.

The Rule of Strict Liability

Strict liability holds people responsible for losses or damages caused by their products or actions, even if they weren't at fault or didn't intend to harm. A harmed person may recover damages under strict liability without needing to prove negligence or accountability. If the action is subject to strict liability laws, the defendant will be held liable even if they post warnings and adopt safety measures. Because of the defendant's actions' extreme potential for harm, it is reasonable to assume that someone will be harmed. This is the basis for strict liability. It is meant to convince those who engage in these types of actions or behaviours to exercise caution. The injured party does not have to prove the offender is guilty; they only need to show that the risky conditions caused their injury. In tort law, the Doctrine of Strict Liability idea only takes into account whether the defendant's actions caused the plaintiff's damage; it ignores the defendant's carelessness, lack of reasonable care, or malice.

Fundamental Elements of The Doctrine of Strict Liability

Involvement of a dangerous substance

The first prerequisite for applying the rule outlined in Ryland v. Fletcher is the presence of a harmful substance. If whatever a person purchased or obtained was dangerous, they are the only ones accountable. What is hazardous may depend on the particulars of the situation, including its facts and circumstances. Poisonous trees, rusty wire, explosives, toxic fumes, and so on are examples of hazardous materials.

Escape from the dangerous substance

The defendant's purchase of a dangerous item must also be escaped for the strict liability rule to apply. "The thing must escape to the area outside the occupation and control of the defendant." The defendant cannot be held accountable if the item did not escape and harm is nevertheless done.

For Example- The defendant's land contains certain toxic plants. The plaintiff's cattle consume leaves from the plant that have entered his land, leading to their demise. The loss will be the defendant's responsibility. On the other hand, the defendant would not be held accountable if the plaintiff's cattle entered the defendant's property, consumed the toxic leaves, and perished.

Un-natural use of the Land

For the rule of severe responsibility to apply, the hazardous object had to be moved into the area of unnatural use of the land. In the Rylands v. Fletcher case, the water collected in the reservoir was considered a non-natural use of the land. The Court held that while storing water for home consumption qualifies as a natural purpose, mill power storage does not. It is imperative to remember that to define what constitutes something "unnatural," there must be a particular application that endangers others.

Exceptions to the rule of Strict Liability

The Default of the Plaintiff-

The strict liability rule cannot be employed if the plaintiff's default or misconduct caused the injury.

According to the ruling in Ponting v. Noakes[3], the plaintiff's horse perished after it wandered onto the defendant's land and consumed some toxic foliage. The court decided that it was an illegal entry and that the defendant should not be held strictly liable for the damage.

By the Act of God-

An event that is not within the control of human agency is called an "act of God." Even with extraordinary caution and foresight, these kinds of behaviours cannot be halted because they are only the result of natural forces. Should the poisonous substance spill as a result of an unpredictable, uncontrollable natural calamity, the accused would not be accountable for the damages.

By the Action of any third party-

Additionally, the rule is not applicable in cases when a third party's actions resulted in damage. By "third party," it is understood that the individual is not the defendant's employee nor does the defendant have any kind of agreement or authority over their job. If the third party's behaviour is predictable, the defendant must take caution.

With the Consent of the aggrieved party

This exception states that the plaintiff forfeits any right of complaint and the strict responsibility rule does not apply if the plaintiff agrees to the defendant's property being used for the collection of dangerous objects. This exception follows the principle laid down by the maxim,’volenti non-fit injuria rule’. The plaintiff may give their express or implicit permission. When the plaintiff firmly expresses his consent, it is considered express consent.

The Rule of Absolute Liability

The Rule of Strict Liability minus the exceptions laid down by the rule leaves behind The Rule of Absolute Liability. The MC Mehta v Union of India case led to the evolution of the absolute liability rule in India.

In the case of MC Mehta v. Union of India, hazardous oleum gas leaked from a Shriram Foods & Fertilizer Industries facility. The surrounding industries and individuals have suffered significant harm due to the gas. The defendant would be accountable for the harm inflicted without taking into account the strict liability rule's exceptions, according to the Apex Court, which subsequently developed the concept of absolute culpability based on the strict liability rule.

There are never any situations when strict liability does not apply, according to the absolute liability rule. Consequently, individuals who damage others will be held completely responsible for making amends and compensating victims fairly. Indian courts have regularly used this rule to prevent it.

Difference between Strict Liability and Absolute Liability

Conclusion

The Rylands v. Fletcher landmark decision had a significant impact on tort law. In numerous cases when the defendant was not careless in inflicting the damage, the strict liability standard outlined in this ruling has been essential in settling the disagreement. Strict liability laws can be used to achieve that aim. It increases the owner's liability for any accidents brought on by the hazardous item he bought. It also ensures that every owner treats these kinds of dangerous traits with the proper prudence.