John Rylands Library Lord Spencer regarded as one of the finest library collections in private ownership with 43,000 items - 3,000 of which originate from before 1501 (i.e. incunabula). Mrs Rylands paid £210,000 for Spencer's collection which included the Aldine Collection and an incunabula collection of 3,000 items. Owens College Library received Richard Copley Christie's library of over 8,000 volumes including many rare books from the Renaissance period in 1901. It was part of the Victoria University of Manchester library from 1904 and was transferred to the John Rylands Library building after the merger in 1972. In 1901, Mrs Rylands paid £155,000 for
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