Rylands v Fletcher Private nuisance requires the claimant to have an interest in land, while "Rylands" does not; although exceptions to this rule have occasionally been made in private nuisance, in "Hunter v Canary Wharf Ltd", the House of Lords ruled that to make exceptions would transform nuisance from a tort against land to a tort against the person, and should not be permitted. John Murphy, Professor of Common Law at the University of Manchester, agrees with Nolan, and makes the additional point that nuisance is focused on a loss of enjoyment to land, not physical damage as "Rylands" is. It has also
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