A case creating a strict liability for an occupier of land who brings and keeps on his land a ‘mischievous thing’ that later escapes and causes damage or injury no matter how careful he has been. In recent times unsuccessful attempts have been made to apply the rule in Rylands v. Fletcher to secure compensation on a strict liability basis for pollutants that have seeped from the defendant’s land. The strict liability rule arises only when there has been ‘non-natural’ use of the land.