John Rylands Library Lord Spencer regarded as one of the finest library collections in private ownership with 43,000 items - 3,000 of which originate from before 1501 (i.e. incunabula). Mrs Rylands paid £210,000 for Spencer's collection which included the Aldine Collection and an incunabula collection of 3,000 items. Owens College Library received Richard Copley Christie's library of over 8,000 volumes including many rare books from the Renaissance period in 1901. It was part of the Victoria University of Manchester library from 1904 and was transferred to the John Rylands Library building after the merger in 1972. In 1901, Mrs Rylands paid £155,000 for
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