From: Donal Nolan <donal.nolan@law.ox.ac.uk>
To: Jason Neyers <jneyers@uwo.ca>
obligations@uwo.ca
Date: 27/05/2009 13:24:43 UTC
Subject: Re: Stephens v Anglian Water Authority

Hi Jason
 
The water that was extracted was water percolating under the defendant's land, and it had been held in the earlier case of Langbrook Properties v Surrey CC [1969] 3 All ER 1424 that even where this resulted in the abstraction of water from underneath the claimant's neighbouring land, with the consequence that the claimant's land or buildings were damaged, no claim would lie.  This was also consistent with Popplewell v Hodkinson (1869) LR 4 Ex Ch 248, where it was held that a landowner did not have the right to have his land supported by water.  Stephens holds that this is so even if the claim is brought in negligence.  Fleming was critical of Stephens (104 LQR 183), and the Restatement, Second, takes a different position (see para 818).    
 
Donal
----- Original Message -----
From:  Jason Neyers
To: obligations@uwo.ca
Sent: Tuesday, May 26, 2009 6:41 PM
Subject: ODG: Stephens v Anglian Water Authority

Dear Colleagues:

I would be interested to find out your thoughts on Stephens v Anglian Water Authority. I have a gut feeling that it is wrongly decided since there seems to me to be a difference between preventing something from getting to the claimant and taking away something that is already on the claimants land. This distinction seems to be missed by the court when they argue that English law gives a 'right' to a land-owner to drain water from her land, which in the context of Bradford Pickles  seems better described as a privilege rather than a 'claim-right'.

Any thoughts,
-- 
Jason Neyers
Associate Professor of Law & 
Cassels Brock LLP Faculty Fellow in Contract Law
Faculty of Law
University of Western Ontario
N6A 3K7
(519) 661-2111 x. 88435