Water from a mill owner's reservoir escaped through old mine shafts and flooded a neighbour's colliery. The House of Lords held the mill owner liable even though he had not been negligent. A person who brings onto his land and keeps there something likely to do harm if it escapes is liable for the damage caused by its escape, provided the use of the land is non-natural.

The House of Lords held that there could be no liability under the rule in Rylands v Fletcher without an escape of the dangerous thing from the defendant's land, clarifying a key element of strict liability.

Solvent spilled at a tannery over many years seeped through the ground and contaminated a water company's borehole a mile or so away. The House of Lords held that the tannery was not liable in nuisance or under Rylands v Fletcher because the damage was not reasonably foreseeable, treating Rylands as an extension of nuisance. It also left the creation of any wider strict liability for hazardous activities to Parliament.

A leak from a council water pipe serving a tower block undermined an embankment and exposed a gas main, and the gas company sought the cost of making it safe under the rule in Rylands v Fletcher. The House of Lords held that supplying water to a block of flats was an ordinary use of land, so the claim failed.