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 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.