John Rylands Library Lord Spencer regarded as one of the finest library collections in private ownership with 43,000 items - 3,000 of which originate from before 1501 (i.e. incunabula). Mrs Rylands paid £210,000 for Spencer's collection which included the Aldine Collection and an incunabula collection of 3,000 items. Owens College Library received Richard Copley Christie's library of over 8,000 volumes including many rare books from the Renaissance period in 1901. It was part of the Victoria University of Manchester library from 1904 and was transferred to the John Rylands Library building after the merger in 1972. In 1901, Mrs Rylands paid £155,000 for
Rylands v Fletcher by "Rylands". Subsequently, "Transco" disapproved of the Australian decision in "Burnie Port Authority v General Jones Pty Ltd" to absorb "Rylands" into the general law of negligence, deciding that "Rylands" should continue to exist but, as Lord Bingham said, as a "sub-species of nuisance...while insisting upon its essential nature and purpose; and...restate it so as to achieve as much certainty and clarity as is attainable". It is now a sub-tort, rather than an independent tort; they have confirmed that it will be allowed to remain. Donal Nolan has argued that to consider "Rylands" as part of private nuisance is unsound.