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

Introduction

Ryland v. Fletcher is a famous English case that established the ‘Rule of Strict Liability’ in the field of law of torts. According to this Rule, “A person is legally accountable for the loss caused to the plaintiff on behalf of defendant notwithstanding the fact that that specific person is not at fault,” This legal doctrine mainly focused on the fact that if any person directly or indirectly engages in an activity that causes harm to the plaintiff, even if that person takes necessary precautions or safety requirements in the absence of fault or criminal intent, that person is legally responsible for the plaintiff’s harm on behalf of the defendant. This rule is sometimes referred to as the “no” fault liability.

Facts of Ryland v. Fletcher

In this case law, Mr. Fletcher (Plaintiff) was the lessee of a coal mine and Mr. Ryland (Defendant) was the owner of a mill. He wanted to construct a water reservoir on his land.

The defendant appointed an independent contractor for the construction of the reservoir.

The Plaintiff had taken a neighboring plot on lease and was working in coal mines.

The workers hired by the independent contractor observed hollow portions in the reservoir while constructing it.

Instead of sealing the hollow portions, they chose to fill them with mud and continued constructing a water reservoir.

After the construction of the reservoir get completed and they filled the reservoir with water.

The water escaping from the holes caused immense damage to the coal mines of the Plaintiff.

The plaintiff filed a suit claiming compensation for the loss caused to him due the negligence on the part of the defendant.

Issues Raised in Rylands v. Fletcher

• Did there seem to be any annoyance?
• Was the Defendant’s use of his land unreasonable, and hence should he be held accountable for the Plaintiff’s damages?

The Court of Liverpool

This court ruled in favour of the plaintiff on both trespass (since the flooding was not “direct and immediate”) and nuisance grounds. Later, a court order resulted in the appointment of an arbitrator from the Exchequer of Pleas in December 1864. The arbitrator determined that the independent contractors were accountable for carelessness because, despite knowing about the old mine shafts, they failed to deal with them properly. Rylands had no means of knowing about the mine shafts, according to the arbitrator, thus he couldn’t be held accountable.

Exchequer of Pleas

After that, the matter was sent to the Exchequer of Pleas. The case was considered on two points, whether the defendants were liable for the contractors’ activities, and whether the defendants were responsible for the harm despite their lack of culpability.

They agreed that the defendants were not liable on the first issue, but they disagreed on the second point. Channell B withdrew his name from consideration. The defendants were not liable, according to Pollock CB and Martin B, because there was no valid case because a negligence claim could not be raised. Dissenting Judge Bramwell B claimed that the claimant had the right to enjoy his land free of interference from water from the defendant’s reservoir, and that as a result, the defendant was guilty of both trespass and nuisance commissioning. He stated that “the general law, wholly independent of contract” should be that the defendants were liable, “on the simple ground that the defendants have caused water to flow into the [claimant]’s mines, which but for their actions wouldn’t have gone there…”

Court of Exchequer Chamber

Fletcher was enraged by the three exchequer judges’ decision and appealed to the exchequer chamber, which consists of six judges. “The prior decision was overturned”, by the six judges. Fletcher.

The Exchequer Chamber court established a guideline for when an owner’s obligation for bringing any danger into his property can arise. At the same time, the court explored some defenses that could help free the defendant of liability.

Rylands was found accountable for the damage done to Fletcher by the Exchequer Chamber court. The defendants owed a duty of care to the risk, according to the court, because they were aware that if that amount of water leaked, it would be dangerous. The defendants showed a lack of care by holding such a large amount of water on their farm, which was an unnatural use of their land. Though it was not dangerous at the moment, it would be dangerous if it escaped.

Rylands felt that this was not just. He went and appealed to the House of Lords.

House of Lords

The House of Lords dismissed Ryland’s appeal. They agreed with the six exchequer judges but went further to feature a limitation on the liability.

Contentions Raised in Ryland v. Fletcher

Mr. Ryland claimed that because he employed an independent contractor, he had no control over their behavior. He is not accountable for an independent contractor’s error. However, one of the Judges decided that Mr. Fletcher had full right to use the land and that because the water escaped from the land, Mr. Ryland was guilty of trespass and so required to pay compensation. Mr. Ryland was found guilty of trespassing, according to the court.

Rationale

The reasoning behind this case is that the defendant is legally responsible for the loss caused to the plaintiff due to the negligence of the independent contractors as per the rule of strict liability.

Conclusion

Ryland v. Fletcher is a famous English case that established the ‘Rule of Strict Liability’ in the field of law of torts. Mr. Ryland claimed that because he employed an independent contractor, he had no control over their behavior. He is not accountable for an independent contractor’s error.

However, Rylands was found accountable for the damage done to the Fletcher by the Exchequer Chamber court. The defendants owed a duty of care to the risk, according to the court, because they were aware that if that amount of water leaked, it would be dangerous. The defendants showed a lack of care by holding such a large amount of water on their farm, which was an unnatural use of their land. Though it was not dangerous at the moment, it would be dangerous if it escaped.

Exceptions to the Rule of Strict Liability

Plaintiff’s Own Fault

When the damage caused to the plaintiff is due to his own fault then the defendant is not liable to provide any compensation for the loss caused to him on the land of Defendant. In the case of Ponting v. Noakes the plaintiff’s horse died after it had reached over the defendant’s land and ate some leaves from the Yew tree. The court rendered the judgement on the behalf of the defendant by stating that the vegetation on the defendant’s land had not spread over to the plaintiff’s side but it was the intrusion of the plaintiff’s horse in the defendant’s land when it chewed on the leaves of the plant sowed in the defendant’s plot. It was a case of the plaintiff himself being at fault, therefore he is not entitled to claim any compensation for the loss caused to him.

Act of God (Vis Major)

When the loss caused to the plaintiff is due to the operation of some natural forces which are so unpredictable that no human force can anticipate it then the plaintiff is not entitled to claim any remedy or compensation for the loss. In the case of Nicholas v. Marsland, the artificial lake was constructed by the defendant over his land which was overflooded due to the heavy rainfall and affected the plaintiff’s house very badly and he claim compensation for the same but the court held that the damages caused to plaintiff was due to the operation of some unexpected natural forces there was no negligence found from the side of the defendant and hence the defendant is not liable to provide any compensation to the plaintiff for the loss caused to him.

Volenti Non-Fit Injuria (Mutual Benefit)

The doctrine of Volenti Non-Fit Injuria works on the principle that ‘consent suffer no harms’ it means that if the plaintiff itself given consent for doing an act which consequently caused injury to him in spite of noting that the fact that the injury is caused by another person. In the case of Smith v. Baker & Sons the plaintiff was a workmen employed by the defendant on working a drill for the purposes of cutting rock and got injured during the course of employment. The house of Lords held that the Plaintiff had not voluntarily undertaken the risk. Thus, the mere knowledge of the risk without the assumption of it does not help in applying the doctrine of Volenti Non-Fit Injuria. While in the case of Peters vs. Prince of Wales Theatre Ltd. Birmingham the court granted the relief of this particular doctrine to the defendant by stating that the defendant not liable as the plaintiff had impliedly consented to the presence of the dangers of a water storage tank situated right next to his shop by taking the defendant’s premises on rent.

Act of Stranger

When the damage caused to the plaintiff due to a wrongful act committed by a third party on the land of the defendant then the defendant is not liable to provide any compensation for the loss caused to the plaintiff. In the case of Rickards vs. Lothian the waste pipe of the wash basin was blocked by some strangers which was under the control of the defendant. The overflowed water from the wash basin damaged the goods of the plaintiff. The court held that the defendant is not liable as the wrongful act is done by the strangers.

Act of Statutory Authority

When the damage is caused to the plaintiff due to the act done under the authorization of law or statute. In the case of Hammer Smith Rail Co. v. Brand, the plaintiff had a land near the railway line which was constructed under the authorization of the government. The value of the plaintiff’s land was depreciated due to the noise and vibrations of the running trains. The court held that the plaintiff is not entitled to claim any damages that were caused to him due to the railway line.

This article has been submitted by Neha Rajput, a student of PSIT College Of Law, Kanpur.