doctrine. In Hanrahan v. Merck, Sharp & Dohme (Ireland) Ltd. [1988] ILRM 629 the supreme court held that in cases of nuisance the burden of proof could be shifted to the defendant where it would be palpably unfair for the plaintiff to have to prove something beyond their reach. The facts concerned poisoning of farm animals downwind of a chemical plant. In Rothwell v. The Motor Insurers Bureau of Ireland [2003] 1 IR 268 the supreme court held the burden of proof would shift when the knowledge is exclusive to the defendant, but also where it is "especially within the range" of the defendant's capacity to probe the facts. South Africa In South African law (which is modelled on Roman Dutch law), there is no doctrine of res ipsa loquitur, although the phrase is used regularly to mean the "facts speak for themselves". Res ipsa loquitur does not shift any burden of proof or onus from one party to the other. The phrase is merely a handy phrase used by lawyers. United Kingdom The doctrine exists in both English law and Scots law. England and Wales In English tort law, the effect of res ipsa loquitur is a strong inference in favour of the claimant that negligence has taken place. It does not however fully reverse the burden of proof (Ng Chun Pui v. Li Chuen Tat, 1988). The requirement of control is important in English law. This requirement was not satisfied in Easson v. LNE Ry [1944] 2 KB 421, where a small child fell off a train several miles after it had left the station. It was considered that the door of the train was not sufficiently under control of the railway company after the train started moving and could have been opened by somebody for whom the company was not responsible. This case was distinguished from the earlier Gee v. Metropolitan Ry where the plaintiff fell from the train immediately after it left the station, when the door through which he fell could still be considered to be fully controlled by the railway company. The requirement that the exact cause of the accident must be unknown is illustrated by the case of Barkway v. South Wales Transport. In this case a bus veered across the road and it was known that the accident was caused by a flat tyre. In this case, the plaintiff could not be