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Giles v Walker
The D is not liable for the escape of a substance that has accumulated naturally.
Hale v Jennings
The accumulated substance must be dangerous in that it is likely to do some mischief if it escapes.
Transco plc v Stockport
The substance accumulated must be dangerous in that it poses an 'exceptional risk'.
Rickards v Lothian
A non-natural use is one that is not commonplace and is not an ordinary use of the land.
Transco plc v Stockport
This case described 'non-natural use' as a use which is 'extraordinary and unusual'.
Cambridge Water v Eastern Counties Leather
The storage of chemicals is a non-natural use.
Read v Lyons and Co
The substance in question must have escaped, in that it moved from land that the D controlled into land that he didn't.
Perry v Kendricks Transport
The D is not liable for an escape caused by the deliberate and unforeseen act of a stranger.
Nichols v Marsland
The D is not liable if the escape is caused by an event which is so enormous that it can neither be foreseen nor guarded against.
Gore v Stannard
It must be the accumulated substance that escapes. For example, if it catches fire and the fire spreads, this is unsufficient.
