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 that in such cases the proprietor is doing something upon his property which is in its nature dangerous and not necessary (or usual?) in the ordinary management of the particular kind of property, and he is therefore bound to observe a higher degree of diligence to prevent injury to his neighbour". The use of "Rylands" in Scots law, which was started in "Mackintosh", finally came to an end in "RHM Bakeries v Strathclyde Regional Council". Lord Fraser, as part of his judgment, stated that the idea of strict liability that was brought into play by "Rylands" was not a part