 Cases brought under "Rylands v Fletcher" now have a requirement that the harm was foreseeable, but it was not defined whether or not it was sufficient that it be foreseeable that harm could occur, or that it be foreseeable that the use of land is "non-natural", that the substance be capable of doing "mischief", and all the other requirements of "Rylands".He also states that the decision did not explain precisely whether "Rylands" should be treated as a development "within" the law of nuisance, or something which sprung "from" nuisance and retains a separate existence.He interpreted the Cambridge Water Company decision as not being sufficient to completely write out "Rylands" as a distinct doctrine; this was later done by the House of Lords in "Transco plc v Stockport Metropolitan Borough Council".