Over 100 years after Rylands v Fletcher, a fourth requirement (to establish liability under the rule) was added, in the case Cambridge Water Co v Eastern Counties Leather plc [1994]. What was it?

Question

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The fourth requirement added in Cambridge Water Co v Eastern Counties Leather plc [1994] is that the defendant must have been able to foresee the consequences of an escape. This means that if the defendant had no way of knowing or predicting that their actions could result in an escape of something harmful, they would not be held liable under the rule.

Over 100 Years After Rylands V Fletcher, a Fourth Requirement