John Rylands "they had become the summit of the firm's hierarchical organization, the seat of its central power and the goal of all ambitious employees" (D. A. Farnie, in "John Rylands of Manchester", 1973). In 1873, Rylands converted his business into a limited company but he retained sole management of it. The extra capital from this move led to the purchase of more mills and the company entered into fresh business in many quarters of the globe. The firm, which had a capital of £2 million, became the largest textile manufacturing concern in the UK. His business made him Manchester's first multi-millionaire.
Rylands v Fletcher been concerned that the reasonable use test, which appears in nuisance, is not applicable to cases brought under "Rylands". The first requirement under "Rylands" is that the defendant "for his own purposes brings onto land and collects and keeps there". In "Rylands", this was the keeping of water in a reservoir; other cases in England and Wales have illustrated what sort of material is considered. In "British Celanese v AH Hunt", the accumulation was of metal foil strips. "For his own purpose" is not understood to be "for his benefit", although that was what Blackburn was referring to at the