Transco plc v Stockport Metropolitan Borough Council
[2003] UKHL 61
판결 이유
The rule in Rylands v Fletcher is a sub-species of nuisance, not a freestanding cause of action. It requires a non-natural use of land and an escape causing foreseeable damage. The rule should not be extended to cover damage to infrastructure on neighbouring land.
사실관계
A water pipe serving a block of council flats fractured, causing an embankment to collapse and exposing a high-pressure gas main owned by Transco.
판결 요약
The House of Lords held that piping water to residential premises was not a non-natural use of land. The rule in Rylands v Fletcher was confirmed as a sub-species of private nuisance with a limited scope of application.
주요 인용문
"The rule in Rylands v Fletcher is a sub-species of nuisance... it should not be the basis of any further extension."
— Lord Bingham
후속 처리
Definitively classified Rylands v Fletcher as part of nuisance law.