John Rylands "they had become the summit of the firm's hierarchical organization, the seat of its central power and the goal of all ambitious employees" (D. A. Farnie, in "John Rylands of Manchester", 1973). In 1873, Rylands converted his business into a limited company but he retained sole management of it. The extra capital from this move led to the purchase of more mills and the company entered into fresh business in many quarters of the globe. The firm, which had a capital of £2 million, became the largest textile manufacturing concern in the UK. His business made him Manchester's first multi-millionaire.
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