University of Manchester Library Mr Simpson had previously been Acting Deputy Librarian of the John Rylands University Library of Manchester until 1985 and subsequently university librarian of the Universities of London and Surrey. Mr Simpson remained until his retirement in December 2007. During the period 2004-07 a major refurbishment of the historic John Rylands Library in the centre of Manchester, together with the construction of new visitor centre, was completed, whilst the Library as a whole merged with the libraries of UMIST and the Manchester Business School to create The John Rylands University Library, University of Manchester. Following Mr Simpson's retirement in 2007, Jan
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.