John Rylands "they had become the summit of the firm's hierarchical organization, the seat of its central power and the goal of all ambitious employees" (D. A. Farnie, in "John Rylands of Manchester", 1973). In 1873, Rylands converted his business into a limited company but he retained sole management of it. The extra capital from this move led to the purchase of more mills and the company entered into fresh business in many quarters of the globe. The firm, which had a capital of £2 million, became the largest textile manufacturing concern in the UK. His business made him Manchester's first multi-millionaire.
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.