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
John Rylands Library archives of the Methodist Church of Great Britain in 1977. Between 1946 and 1988 a number of sections of the Earl of Crawford's library were deposited here, however all but one of these were withdrawn in 1988. Mrs Rylands died in 1908 having bequeathed her private collections and an endowment of £200,000 to enable the library to expand. The funds were used to acquire 180,000 books, 3,000 manuscripts and extend the building. The Librarian, Henry Guppy, invited individuals to deposit their archives for safe keeping in 1921 when there were no county record offices in Lancashire or Cheshire and the