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 leading to the development of negligence and nuisance and the further development of trespass. At the time of "Rylands", the previous case relied upon was "Vaughan v Menlove", decided in the Court of Common Pleas in 1837. The case had almost identical facts to "Rylands", but strict liability was never even considered. The case is instead thought of as one of the best attempts of early 19th century English judges to build up the law of negligence. The outcome of "Rylands" meant that judges would again impose strict liability on defendants who accumulated dangerous things on their land without any