How have courts dealt with nuisance claims in the context of subtenancies?

In Cunard and Wife v. Antifyre Limited [1933] 1 K.B. 551 the plaintiff and his wife occupied a flat on the third floor of a building. He was in possession by virtue of a monthly sublease granted by the tenant of that and other floors of the building. The tenant was the lessee of the defendant. The wife was personally injured in circumstances that amounted to a nuisance on the part of the defendant, if it were actionable by her. She claimed in both nuisance and negligence and recovered on negligence. The claim in nuisance was treated cursorily. Counsel for the wife argued that Malone v. Laskey was distinguishable because there the husband was not a tenant and had no estate whatever in the premises. Talbot, J. at page 557 disposed of the issue shortly, saying that "* * * it would manifestly be inconvenient and unreasonable if the right to complain of such interference extended beyond the occupier * * *" For this he relied on Malone v. Laskey.