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 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