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In Rylands v Fletcher, the reservoir water escaped and flooded:

In Rylands v Fletcher (1868) LR 3 HL 330, reservoir water passed through old mine workings into the plaintiff's coal mine. The resulting flooding involved an "escape" from…

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In Rylands v Fletcher, the reservoir water escaped and flooded:

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In Rylands v Fletcher (1868) LR 3 HL 330, reservoir water passed through old mine workings into the plaintiff's coal mine. The resulting flooding involved an "escape" from the defendant's land, rather than damage to a railway or highway.

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