Crown River Cruises Ltd v Kimbolton Fireworks [1996] 2 Lloyd’s Rep. 533
Nuisance – Fireworks – Physical Damage to Property
Facts
The defendants, Kimbolton Fireworks, carried out a short firework display that lasted for some twenty minutes or so. As a result of the fireworks display, some burning debris landed on the claimant’s river barge which had been moored on the river on their property, and set fire to it causing it damage. The area was rural, and the river boat was moored permanently in place. The claimants sued in private nuisance and the defendants alleged, firstly, that a nuisance could not be constituted in law by an action lasting only twenty minutes, and secondly that as it was a boat that was damaged and not their ‘land’ itself, this was not actionable in nuisance.
Issues
Whether or not a nuisance could be constituted by even an act that was short in duration. If so, whether or not the claimant’s had a cause of action considering that it was the defendant’s river boat which was damaged rather than the underlying land itself as a result of the nuisance.
Decision/Outcome
The claim was allowed. There was a nuisance in this particular case even though the firework display only lasted for such as short period of time. The claimant’s barge was moored permanently in place, and as such it could be considered to be an extension of the claimant’s land. As this was physically damaged by the defendant’s actions, following St Helen’s Smelting Co v Tippings [1865] 11 HL Cas 642 it could not be said that the locality of the area was a defence to the harm caused.
Updated 19 March 2026
This article accurately summarises the decision in Crown River Cruises Ltd v Kimbolton Fireworks Ltd [1996] 2 Lloyd’s Rep 533. The core legal principles described — that a private nuisance may arise from a single short-duration event where physical damage results, and that a permanently moored vessel may be treated as an extension of the occupier’s land for the purposes of nuisance — remain good law and have not been overturned or materially qualified by subsequent legislation or case law. The reliance on St Helen’s Smelting Co v Tipping (1865) 11 HL Cas 642 for the proposition that physical damage to property cannot be answered by a locality defence is also still an accurate statement of the law. The article should be read alongside the broader development of private nuisance law following Fearn v Board of Trustees of the Tate Gallery [2023] UKSC 4, in which the Supreme Court clarified several foundational principles of nuisance, though that decision does not alter the specific propositions addressed in this case. The article remains suitable for its intended purpose.
