October 3, 2025
Read v J Lyons & Co Ltd [1946] UKHL 2
An inspector in a munitions factory was injured by an explosion. She could not prove negligence. The House of Lords held the factory was not liable under the rule in Rylands v Fletcher as there was no 'escape' of the dangerous thing from the premises. Facts The appellant, Miss Eleanor Read, was an inspector for the Ministry of Supply during the Second World War. She was directed to work at the respondent’s munitions factory, which was operated on behalf of the Ministry. On 31st August 1942, an explosion occurred during the process of manufacturing a high-explosive shell, killing one person