The claimant was employed by the
defendant in their factory which made explosives for the Ministry of Supply. During
the course of her employment an explosion occurred which killed a man and
injured others including the claimant. There was no evidence that negligence
had caused the explosion. At trial the judge held that the case was governed by
the rule in Rylands v Fletcher and liability was therefore strict. The Court of
Appeal reversed this decision as the rule in Rylands v Fletcher required an
escape of the hazardous matter. The claimant appealed. The House of Lords
dismissed the appeal. In the absence of any proof of negligence on behalf of
the defendant or an escape of dangerous thing, there was no cause of action on
which the claimant could succeed.
Read v Lyons
