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[1996] 2 Lloyd's Rep 533 (QBD). The claimants, who operated a permanently-moored river barge on the Thames, sued the organizers of a firework display in private nuisance and Negligence, and the local fire authority in negligence, when their vessel was damaged by firework debris. It appears that falling debris started a small fire on the claimant's barge, which the fire authority failed properly to extinguish, so that it subsequently became a large fire. The was also some dicussion of whether the RuleInRylandsVFletcher could extend to cases of this sort, but this argument was not fully developed.

The actions in nuisance and negligence against both defendants succeeded, predictably enough. What is interesting about this case is that it decided that a river barge could constitute 'land' for the purposes of private nuisance; in addition, the operators of the barge were merely licencees, and under the rule in MaloneVLaskey1907, would not normally have been able to sustain an action in nuisance at all. However, this latter point has to be considered in the light of HouseOfLords decision in hunter v canary wharf (1997).