Rylands v Fletcher Private nuisance requires the claimant to have an interest in land, while "Rylands" does not; although exceptions to this rule have occasionally been made in private nuisance, in "Hunter v Canary Wharf Ltd", the House of Lords ruled that to make exceptions would transform nuisance from a tort against land to a tort against the person, and should not be permitted. John Murphy, Professor of Common Law at the University of Manchester, agrees with Nolan, and makes the additional point that nuisance is focused on a loss of enjoyment to land, not physical damage as "Rylands" is. It has also
Rylands v Fletcher been concerned that the reasonable use test, which appears in nuisance, is not applicable to cases brought under "Rylands". The first requirement under "Rylands" is that the defendant "for his own purposes brings onto land and collects and keeps there". In "Rylands", this was the keeping of water in a reservoir; other cases in England and Wales have illustrated what sort of material is considered. In "British Celanese v AH Hunt", the accumulation was of metal foil strips. "For his own purpose" is not understood to be "for his benefit", although that was what Blackburn was referring to at the