Miles v Forest Rock Granite Co (Leicestershire) Ltd (1918) 34 TLD 500
Escape of something naturally occurring on the premises through non-natural use of land
Facts
The defendant had brought some explosives onto his land and used them to blast rocks which had already been naturally occurring on his land. As a result of this blasting, some of the rock fragments flew onto nearby land below, more specifically on the nearby highway, where they hit and injured the claimant. The claimant brought an action under the rule in Rylands v Fletcher, which had established strict liability for damage done as a result of an escape of a thing from one’s land which was brought onto the land by the defendant and which could be expected to cause such damage.
Issues
The issue in this case was whether the fact pattern fit the rule in Ryland v Flecther which related to damage done by things not naturally occurring on the defendant’s premises, whereas in this case the damage was done by rocks which had been naturally occurring and which the defendant had not brought onto his premises.
Decision/Outcome
The court held that there was strict liability here as per Rylands v Flecther, since there had been an escape of a sorts, namely the blast. While the rocks were not brought onto the land, the defendant had brought the explosives onto his land which caused the rocks to fly out through the blasting. A non-natural use of the land could in effect extend the rule to damage done by naturally occurring objects.
Updated 20 March 2026
This article accurately states the core legal principle from Miles v Forest Rock Granite Co (Leicestershire) Ltd (1918): that the rule in Rylands v Fletcher (1868) LR 3 HL 330 can extend to naturally occurring things on land where a non-natural use of the land (here, the introduction of explosives) causes their escape. This extension of Rylands v Fletcher liability remains good law.
Readers should note that the broader rule in Rylands v Fletcher itself was significantly considered and narrowed by the House of Lords in Cambridge Water Co v Eastern Counties Leather plc [1994] 2 AC 264, which confirmed that foreseeability of damage of the relevant type is required, and further by Transco plc v Stockport Metropolitan Borough Council [2003] UKHL 61, which emphasised that non-natural use requires something out of the ordinary and that the rule applies only to an exceptionally dangerous or mischievous thing. Neither case overrules the principle applied in Miles, but students should read this case within that wider and more restrictive modern framework. The article does not address those later developments, which are important to a full understanding of this area of law.
