injured in a factory explosion), the court distinguished Rylands v Fletcher (1868) because in the present case, even though the defendant factory kept "dangerous things on the land for a non-natural user", there was "no escape". Obiter followed Where an obiter dictum (a non-binding statement based on hypothetical facts) is subsequent followed and adopted, then the later case is said to "approve" that obiter, and the earlier case may be marked "approved", "followed", or "obiter followed". See also Case law Opinion Precedent Persuasive authority Binding authority References Legal reasoning