John Rylands Library and other impurities'. This, and the overcrowded site, created many design problems for the architect. During the century most textile manufacture moved to newer mills in the surrounding towns while Manchester remained the centre of trading in cotton goods both for the home and foreign markets but pollution from burning coal and gas remained a considerable nuisance. The site chosen by Mrs Rylands was in a central and fashionable part of the city, but was awkward in shape and orientation and surrounded by tall warehouses, derelict cottages and narrow streets. The position was criticised for its lack of surrounding space
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.