Case Analysis |Ryland v. Fletcher [1868] UKHL 1, (1868) LR 3 HL 330

Facts-

The defendants employed certain independent contractors for constructing the reservoir on his land to provide water to their mill. Under the site of the reservoir the contractors found some disused mines while digging but they failed to properly block them. When the reservoir was filled with water, it burst and the water get ran through the mineshafts into the plaintiff’s land which was on adjoining land flooded. As a result, the plaintiff sued the defendants for his negligence though the mistake was of the independent contractors.

Issues

1. Whether the use of defendant’s land unreasonable and was he liable for the damages suffered by the plaintiff?

2. Whether this case was of the negligence on the part of the defendant, though he was unaware of the facts?

Arguments (Plaintiff’s side)

The plaintiff went to the Court against the defendant and the Court gave its decision in the favor of the plaintiff and held the defendant liable on the basis of nuisance and trespass. Later a court order led to an arbitrator from the Exchequer of Pleas, who was appointed in December 1864. The arbitrator firstly observed the case and decided that the independent contractors were liable for negligence since they had known about the old mine shafts, but still showed negligence while working on the same. The arbitrator said, Ryland’s, had no way of knowing about the mine shafts, so he couldn’t be liable.

Arguments (Defendant’s side)

Fletcher being aggrieved by the decision of the Exchequer of pleas appealed in the Court of Exchequer Chamber. They ordered in favor of the defendant and held that the defendant is liable for the act if he knows about them and act negligently. The court held that the defendants owed a duty of care towards the risk, as they were aware of the fact that if that quantity of water would escape, it would be harmful. There was a want of care by the defendants, as they were doing unnatural use of their land by storing that huge quantity of water. Rylands appealed to the House of Lords.

Judgment

The Ryland’s appeal was dismissed by the House of Lords and they agreed with the Exchequer Judges and only add one thing limitation on liability. They also mentions that the use of the land must be unnatural and the thing which escapes must not be in the control of the defendant to make him liable. They also give three principles in this case from which the ‘Strict Liability’ can be recognized:-

1.  Some dangerous thing must have been brought by a person on his land.

2. The thing which was brought by the person must be escape.

3. Must be unnatural use of land.

Analysis

The rule which was laid down in this case created a huge impact in the cases in which owner’s liability is questionable. The rule of ‘Strict Liability’ confers a duty on the person when he is bringing any dangerous substance in his land and thus increases his duty towards the other people. This case is also very important for the perspective of India also because we are on our developing phase and in this era this rule is highly impacted.

In the case of MC Mehta also the principle of ‘Absolute Liability’ was laid down due to the preference of the ‘Strict Liability’. Thus, I think this rule created a responsibility on the person to take care of the dangerous things which can be harmful for other people.

The rule in this case has paved the way for our Indian Judiciary to look into the matter of such cases in which whether the owner is negligent or not is not in question but he has to be made liable for all the damages.

The rule of ‘Strict Liability’ is very important in the era of modernization to make the person responsible for all the conduct either he is doing intentionally or negligently. This creates an obligation to use the premises in very reasonable manner and not to create any hustle to the neighboring people.

Also, because of this principle the ‘Absolute Liability’ came into picture which is one of the most useful principle in today’s era.