John Rylands He was buried in the Southern Cemetery, Manchester: a fine tomb was erected over the vault and his widow was buried there in 1908. The tomb was designed by C. H. Heathcote and completed in 1892. The elaborate superstructure of the tomb which included four angels was taken down in 1927 after it was vandalised and the bronze railings were stolen in 1967. His estate, the bulk of which was left to his wife Enriqueta, was valued at £2,574,922 (£ as of ), greater than that left by any other cotton manufacturer to that time. "Rylands v Fletcher", an important
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