The Fire Prevention (Metropolis) Act 1774, Section 86, states that no action can be brought against anyone whose premises a fire starts by accident. Accidental fire was defined in Filliter v. Phippard (1847) as “fire produced by mere chance or incapable of being traced to any particular cause.” Thus, if the cause of the fire is negligence, nuisance, or a Rylands v. Fletcher object, the fire is not ‘accidental,’ and the defence under s.86 is inapplicable. It appears that any liability for fire was intended to be fault-based.