Anthony v. Coal Authority

The claimants succeeded in a nuisance claim alleging smoke nuisance from the spontaneous combustion of colliery spoil heaps. Whist the spoil heaps had not comprised a foreseeable nuisance at the time of their creation, when their use had been reasonable, they subsequently became a foreseeable risk and a danger after closure of the colliery, so that the defendant was in a situation which was comparable to an occupier who had to take care as a result of the acts of trespassers and forces of nature which rendered his land dangerous to neighbours. Once fixed with knowledge of that risk, the question was as to the reasonable steps which were required in the circumstances to abate it.