“Rylands v Fletcher requires escape from defendant's land for strict liability”
Read was a munitions inspector working in Lyons' munitions factory during wartime. An explosion occurred in the factory without any negligence on Lyons' part, injuring Read. Read sued under the rule in Rylands v Fletcher, arguing that Lyons was strictly liable for the explosion of dangerous materials on their premises.
Whether liability under Rylands v Fletcher can arise without an escape of the dangerous thing from the defendant's land onto neighboring property.
The House of Lords held that Lyons was not liable. There could be no liability under Rylands v Fletcher without an escape from the defendant's land.
This case significantly restricts the scope of Rylands v Fletcher by confirming that escape is an essential element. It clarifies the boundaries between strict liability and negligence and remains the leading authority on the escape requirement.
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OSCOLA Citation
Read v J Lyons & Co [1947] AC 156
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