Enriqueta Augustina Rylands Manchester and the library she had founded). She received the honorary degree Doctor of Literature (D.Litt.) from the Victoria University in February 1902, in connection with the 50th jubilee celebrations of the establishment of Owens College. In 1901, Mrs Rylands paid £155,000 for more than 6,000 manuscripts owned by James Lindsay, 26th Earl of Crawford of Haigh Hall. The "Bibliotheca Lindesiana" was one of the most impressive private collections in Britain at the time, both for its size and the rarity of some of its contents. A full-length statue of Mrs Rylands, by Manchester sculptor John Cassidy, was commissioned by
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