Thursday, 7 July 2022

Case analysis Rayland v Fletcher

 Case analysis Rayland v Fletcher

In cases of torts, the general rule is that the person who causes damage to other person either intentionally or via his negligence shall pay damages to the affected party. This rule however, if followed strictly leads to many problems. For example, if I bought an explosive material on my house to do some experiment and it explodes without my negligence or knowledge on its own.


Can I Be held liable? Surely not, as there was neither any intention to cause harm nor any negligence is there. Thus, his rule is somewhat absurd. To solve the issues caused by this rule, the House of Lords in Rylands v/s Fletcher propounded a new rule called as “Rule of Strict liability” or “No Fault Liability”. According to this rule, a person can be held liable even there is no negligence on his part.


Case Name: Rylands v/s Fletcher – Citation: UKHL 1, L.R. 3 H.L. 330.

Judges: Lord Cairns and Lord Cranworth – Date of Judgement- July 17, 1868


Facts of the Case

The defendant, Rylands constructed a reservoir over his land for providing water to his mill via independent contractors. There were some old disused shafts under the reservoir which the contractors failed to notice. As a result these shafts remained unblocked. When the water was filled in the reservoir, it burst through the shafts and flooded the plaintiff’s coal mines on the neighbouring land. Though there was no negligence on the part of the defendant, Rylands, the plaintiff, Fletcher sued the defendant for damages.


Issues:

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?


Judgement

Court of Liverpool

The Court of Liverpool gave its judgement in the favour of defendant holding that there was neither any trespass (as the flooding was not direct and immediate) nor any nuisance (as the flooding was not a continuous event, it is a one off event). Later, in December, 1864, via a Court order an arbitrator was appointed for the case. The arbitrator too decided in favour of the defendant by stating that the defendant had no way of knowing about the mine shafts so he could not be held liable. The arbitrators however, held the contractors liable for their negligence.


Court of Exchequer of Pleas

The case afterwards went to Exchequer of appeals for hearing.


The Court heard this case on two issues:

Whether the defendants were liable for the actions of the contractors

Whether the defendants were liable for the damage regardless of their lack of negligence

The Court unanimously decided that the defendant was not liable for the actions of contractors but have mixed views on the second issue. While Pollock CB J. and Martin B J. held that the defendants were not liable as there was no negligence on part of defendant, Bramwell B. J. held that the defendant was liable as the claimant had the right to enjoy his land free of interference from water and it was the defendant’s act (i.e. act of building reservoir) which actually caused flooding of water on claimant’s land and thus held the defendant liable for trespass and nuisance.


Court of Exchequer Chamber

Aggrieved by the decision of Court of Exchequer of Pleas, Fletcher appealed to the Exchequer Chamber composed of six judges. The judges overturned the decision of Court of Exchequer of Pleas. It was in this Court where the rule of Strict liability was first time propounded.

Conclusion

The landmark judgment of Rylands V Fletcher played a vital role in law of torts. The rule of strict liability propounded in this case has been instrumental in solving many disputes where the damage is caused without any negligence on part of defendant. In this fast changing 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 onerous to bear the responsibility of every damage which that thing may cause.


The rule of strict liability helps us in achieving that objective. It places an additional burden on the owner to bear the responsibility of all catastrophes that may be caused by the dangerous thing he has bought. Moreover, it also ensures that every owner exercise proper care in handling such dangerous properties.


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