State ex rel. Henry v. Superior Court
In State ex rel. Henry v. Superior Court, 155 Wash. 370, 284 P. 788 (1930), the Court reviewed an order of necessity for a pipeline easement to carry water to arid land requiring irrigation to produce commercial crops. There the fact the land to be irrigated was separated from the water source by another's land was not determinative.
Rather, the Court emphasized the water was necessary for the proper use and enjoyment of the land because it would be rendered worthless without irrigation:
Respondent's orchard land is so situated, with respect to the only source of water and the land of the relators, that it is necessary for its proper use and enjoyment to have and maintain a private way of necessity for a pumping location and pipe line on and across relators' land to force and carry water for irrigation purposes to the respondent's orchard, else the orchard will become worthless. Henry, 155 Wash. at 376.