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Ryland v/s Fletcher And The Rule Of Strict Liability

A person is generally; liable for all the wrongs committed by him. However, there are certain instances where an individual can be prosecuted for an event despite taking necessary precautions and with no fault or intentions on his part. Strict liability is one such principle that makes a person accountable by recognizing ' no fault liability'.

It was the judgment given in the landmark case of Ryland v Fletcher which laid down this legal doctrine that incurs liability on a party without the plaintiff having to prove negligence on the part of the defendant.

Ryland v. Fletcher And The Rule Of Strict Liability

Citation: [1868 ] L. CITAR. 3 H.L. 330
Name Of Parties: Petitioner: Ryland v/s Respondent: Fletcher
Judges: Lord Cairns and Lord Cranworth

Facts
The defendant got a reservoir constructed over his land to provide water to his mill through an independent contractor. The old disused shafts which had been present under the reservoir were not noticed by the contractors as a result, they remained unblocked. When water was filled in the reservoir, it burst through the shafts and gushed to the adjoining coal mines of the plaintiff, damaging his property.

The defendant who possessed no knowledge of the shafts was not negligent on his part.

Issues:
  1. Was the defendant's use of land unreasonable?
  2. Should he be made for all the damages caused to the plaintiff?

Judgement:
The Court Of Liverpool
The Court of Liverpool sided with the defendant declaring him not guilty and further held that there was neither any trespass nor any nuisance.

Later, an arbitrator who was appointed in December 1864 by court order also declared that the defendant can't be held liable as he wasn't aware of the mine shafts, further it was the independent contractors who were negligent as they failed to block the shafts.

Court Of Exchequer Pleas
The Court of Exchequer entertained the appeal from the lower court and sided with the view that the defendant could not be held liable for the acts of the independent contractors. However, they had mixed opinions on the matter of whether the defendant was liable for the damage sustained by the plaintiff or not.

Court Of Exchequer Chamber
unsatisfied with the decision of the lower court, Fletcher appealed to the Court of Exchequer Chamber. The six judges of the chamber overturned the decision of the lower court establishing the principle of Strict Liability which states that if a person makes non-natural use of land or brings any dangerous thing onto his premises which on escaping causes damage, then that individual will be liable for all the damage sustained by the plaintiff.

House Of Lords
The House of Lords did not entertain Ryland's appeal and agreed with the verdict given by the Court Of Exchequer Chamber.

Essential Elements Of Strict Liability
There must be the presence of 3 essential elements to constitute strict liability. They are as follows:
  1. Dangerous Thing
    Some dangerous thing must have been brought by a person on his land. Some examples of Dangerous things are- toxic gases, rusty wires, explosives, etc.

    illustration: the defendant planted poisonous trees on his land whose branches protruded into the neighbour's house. The plaintiff's cattle died after consuming the leaves of the trees. The court held the defendant liable for the same.
     
  2. Escape
    The dangerous thing brought by a person on his land must also escape the premises to be out of the reach and control of the defendant. In the case of Mrs Read v Lyons & Co, it was held that since there was no escape of dangerous things, therefore, there was no liability on the part of the defendant.
     
  3. Non-natural Use Of Land
    Finally, to make a person strictly liable, the defendant must make a non-natural use of his land which must be bringing with it increased danger to others. In the case of T.C. Balakrishnan Menon v. T.R. Subramanian, it was held that the use of explosives in an open ground even on a day of the festival is a non-natural use of land.

Exceptions:
There are 5 defences that a person can plead in a court of law to escape from being held strictly liable. they are as follows:
  1. Plaintiff's own default
    A plaintiff can not claim compensation for the loss sustained by him because of his very own actions. In the case of Ponting v. Noakes, the defendant was not held liable for the death of the plaintiff's horse who trespassed on his land and nibbled on the leaves of poisonous trees, as it was the plaintiff who was in wrong.
     
  2. Act of God
    No liability can arise from acts or events which are beyond the control of any human agency and are known as 'Acts of god'. The very same principle was applied in the case of Nikolas v Marshland where an extraordinary rain destroyed the defendant's embankment because of which the plaintiff's property was flooded by water causing a lot of damage to him.
     
  3. Consent Of Plaintiff
    When a plaintiff consents to the presence or accumulation of dangerous thing on the defendant's premises, he gives up his right to claim compensation, in case he suffers any loss. This legal doctrine was applied in the case of Carstairs v. Taylor.
     
  4. Act Of 3rd Party
    A person can not be made liable for the acts committed by a 3rd party. In the case of Box v. Jubb, the drainage system of the defendant's reservoir was clogged by a 3rd party which caused the water to overflow. The court of law didn't hold the defendant liable for the same.
     
  5. Statutory Authority
    The principle of strict liability can not be applied in cases where an individual suffers damage by an act that has been authorized by the legislature.

Conclusion
The principle proposed in the landmark case of Ryland v. Fletcher plays a pivotal role in resolving disputes where a party suffers damage despite the defendant not being negligent. It is of utmost relevance in today's era of globalization where a person can be made accountable for bringing dangerous thing onto his premises which causes loss to others on escaping.

Written By: Aina Islam

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