Read v Lyons [1947] AC 156  House of Lords

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.

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