John Rylands Library of the John Rylands Library" in 1903; it later became a journal publishing academic articles and from autumn 1972 the title was changed to the "Bulletin of the John Rylands University Library of Manchester" (further slight changes have occurred since). During the First World War 11 members of staff joined the armed forces; of these only Capt. O. J. Sutton, MC, lost his life while serving. Other noteworthy members of staff were James Rendel Harris, Alphonse Mingana, the Semitic scholar Professor Edward Robertson (d. 1964) who was the third librarian, and Moses Tyson, keeper of western manuscripts, afterwards librarian of
Rylands v Fletcher principle, in "Losee v. Buchanan", "Brown v. Collins", and "Marshall v. Welwood" respectively. The Supreme Court of New Jersey, however, reversed "Welwood" in 1983 in "Department of Environmental Protection v. Ventron Corp". Many courts in the United States have attempted to use "Rylands" to justify absolute liability, which it was never intended to do; while absolute liability is where no defence is applicable, in "Rylands" itself Lord Cairns accepted that there were some situations where the case should not be applied. In Australia, the principles of "Rylands v Fletcher" were "killed off" by the High Court of Australia in "Burnie