University of Manchester Library in 1904. In July 1972 this library merged with the John Rylands Library to become the John Rylands University Library of Manchester (JRULM). On 1 October 2004 the library of the Victoria University of Manchester merged with the Joule Library of UMIST forming the John Rylands University Library (JRUL). The Joule Library was the successor of the library of the Manchester Mechanics' Institute (established in 1824) which later became the library of the University of Manchester Institute of Science & Technology (UMIST). One of the Institute's first actions was to establish a library, with a full-time librarian, at premises in
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