In what circumstances have golf balls been found to have landed on a plaintiff's property?

In Lester-Travers v. The City of Frankston [1970] V.R. 2, golf balls played by golfers on two holes and the practice fairway landed on the plaintiff’s property, some striking her house and others simply landing in her grounds. In a period of about twelve months at regular intervals at least thirty-six golf balls had so intruded. Occasionally slight property damage had been done. The court concluded that the intrusion of golf balls had substantially interfered with the plaintiff’s use and enjoyment of her property and therefore constituted a private nuisance. It awarded her damages and an injunction.