Heading – John Ryland and John Horrocks vs Thomas Fletcher
Citation –John Ryland and John Horrocks vs Thomas Fletcher (1868) UKHL 1, (1868) L.R. 3 H.L. 330
Names Of Judges Involved in the Judgment – Lord Cairns and Lord Cranworth
Ryland vs Fletcher (1868) is one of the most famous cases and landmark cases of tort law. In this case the House of lords declared the rule No fault liability. The rule of strict liability is organized in this case. By this rule a person may be liable for some harm even though he or she is not negligent in causing the same. This is the way of absolute liability in India. Major contribution of the rule of strict liability originated in this case. This case was decided on 17 July 1868.
FACTS OF CASE
Ryland and Fletcher both were neighbors.
Ryland owned a mill for which energy was required.
He constructed a water reservoir on his land.
He gave it to the independent contractor and engineers.
There were some old shafts under the site of the reservoir. The contractor did not observe these shafts even though the defendant did not know about shafts.
Due to the negligence of the private contractor the shafts that led the way to Fletcher's mine were broken which led the water into the mine causing heavy loss to him.
The negligence was on the part of an independent contractor.
Fletcher sued the Ryland.
ISSUES OF THE CASE
Whether there was any nuisance or not?
Was the use of defendant's land unreasonable and thus was he to be held liable for damages incurred by the plaintiff?
JUDGMENT OF THE CASE
The Court of Liverpool
This court ruling favored the plaintiff on the basis of both
trespass (as the flooding was deemed not to be direct and immediate) and nuisance.
Later a court order led to an arbitrator from the exchequer pleas who was appointed in December 1864.
The arbitrator decided that the independent contractor was liable for negligence since they had known about the old mine shafts and still showed negligence in dealing with it.
The arbitrator said Ryland had no way of knowing about the mine shafts so he couldn’t be liable.
The 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 liability.
The house of lords dismissed the appeal and agreed with the six exchequer judges.
Lord cairns while speaking for the house of lords, stated above by justice Blackburn in the court of exchequer chamber but included a further limitation on liability
The one more requirement is that land from which the escape occurs must have been modified in a way which would be considered non-natural, unusual or inappropriate.
The judgment of this case was delivered on 17 July.
In this case consisted of only two judges, Lord Cairns and Lord Cranworth;Lord Colonsay didn’t attend the case.
ESSENTIAL OF STRICT LIABILITY
There are three essentials of strict liability
1 Some dangerous thing must have been brought by a person on his land.
2 The thing thus brought or kept by an individual on his land must escape.
3 It must be non- non-natural use of land.
RATIO DECIDENDI (REASON OF DECIDING)
Facts
Ryland constructed a reservoir on his land.
The work of construction was done by an independent contractor and he was negligent in his work.
Water escaped and injured fletcher.
Conclusion – Ryland was held liable to fletcher.
Material facts seen by the court
Ryland constructed a reservoir on his land.
Water escaped and injured fletcher.
Conclusion – Ryland was held liable to fletcher.
CONCLUSION
The landmark judgment of Ryland v Fletcher played a vital role in the law of torts. The rule of strict liability propounded in the case has been in solving many disputes where the damages is caused without any negligence on part of the defendant. In today's world where industrialization and technological advancements are taking place rapidly it is necessary that the owner who makes use of dangerous things shall be made the responsibility of every damage which that thing may cause. The rule of strict liability helps us in achieving that objective. It also ensures that every owner exercises proper care in handling.
This article is written by Riya Yadav of Trinity institute of professional studies.