In his valuable article ‘Dangerous Things and the Non-Natural User of Land,’ Mr. Stallybrass says: ‘The distinction between the natural and non-natural user of land is often confused with the distinction between things naturally on the land and those which are brought or artificially created there. We have already seen that to some extent this confusion can be detected in Lord Cairns’ speech itself [in Rylands v. Fletcher]. But in fact there is nothing in common between the two conceptions except the common use of the word “natural.”’