 Newark in 1949, in which Newark called the decision in "Rylands" "a simple case of nuisance" rather than a revolutionary doctrine that established strict liability outside nuisance.Goff also found similarities between the principle of "non-natural use" under "Rylands" and that of the "reasonable user" requirement in nuisance, concluding that "[I]t would lead to a more coherent body of common law principles if the rule [in "Rylands"] were to be regarded essentially as an extension of the law of nuisance".Lord Goff's judgment was primarily based on whether or not foreseeability of damage should be a factor in "Rylands" cases, and was that the matter was "open for consideration", saying that the need for foreseeability of damage to be a criterion was "a matter of principle".