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 leading to the development of negligence and nuisance and the further development of trespass. At the time of "Rylands", the previous case relied upon was "Vaughan v Menlove", decided in the Court of Common Pleas in 1837. The case had almost identical facts to "Rylands", but strict liability was never even considered. The case is instead thought of as one of the best attempts of early 19th century English judges to build up the law of negligence. The outcome of "Rylands" meant that judges would again impose strict liability on defendants who accumulated dangerous things on their land without any