 Secondly, it was the first decision to state that "Rylands" may be a sub-set of nuisance, and as such applied the same requirement of foreseeability of harm to nuisance, where previously such a requirement had not existed.Academic Tom Clearwater criticises some of the language Lord Goff picked out of "Rylands v Fletcher" for his judgment.In particular, Goff's use of "anything "likely" to do mischief if it escapes" and "answer for the natural and "anticipated" consequences" to justify his argument that "Rylands" had always intended foreseeability to be a factor suggests Goff "[overstepped] an appropriate reach of interpretation in drawing his conclusion...most cases gloss silently over the [wording]... three cases imply that foreseeability of damage is not a relevant consideration at all".