University of Manchester Library Mr Simpson had previously been Acting Deputy Librarian of the John Rylands University Library of Manchester until 1985 and subsequently university librarian of the Universities of London and Surrey. Mr Simpson remained until his retirement in December 2007. During the period 2004-07 a major refurbishment of the historic John Rylands Library in the centre of Manchester, together with the construction of new visitor centre, was completed, whilst the Library as a whole merged with the libraries of UMIST and the Manchester Business School to create The John Rylands University Library, University of Manchester. Following Mr Simpson's retirement in 2007, Jan
Rylands v Fletcher principle, in "Losee v. Buchanan", "Brown v. Collins", and "Marshall v. Welwood" respectively. The Supreme Court of New Jersey, however, reversed "Welwood" in 1983 in "Department of Environmental Protection v. Ventron Corp". Many courts in the United States have attempted to use "Rylands" to justify absolute liability, which it was never intended to do; while absolute liability is where no defence is applicable, in "Rylands" itself Lord Cairns accepted that there were some situations where the case should not be applied. In Australia, the principles of "Rylands v Fletcher" were "killed off" by the High Court of Australia in "Burnie