Meering v Graham-White Aviation Co Ltd [1920] 122 LT 44

Facts

• The case concerned a claim of false imprisonment, focusing on the unlawful restriction of a person's freedom of movement.
• Key issues included whether total restraint is necessary for false imprisonment and whether awareness of confinement by the claimant is required.
• The court referenced prior cases, including Bird v Jones and Heard v Weardale Steel, Coal & Coke Co, to illustrate the boundaries of the tort and the role of voluntary submission to confinement.
• The court also considered distinctions between the powers of police constables and private prosecutors in detaining individuals.

Issues

1. Whether false imprisonment requires physical restraint or the claimant’s awareness of restraint.
2. Whether total restraint, rather than partial obstruction, is necessary to establish false imprisonment.
3. The role of the absence of lawful authority and improper motives in claims of false imprisonment.
4. The procedural requirements for the recording of witness depositions in criminal proceedings.

Decision

• The court held that physical contact is not required for false imprisonment; total restraint alone is sufficient.
• Awareness of confinement by the claimant at the time of restraint is not necessary for a valid claim.
• Partial restraint, as opposed to total restraint, does not amount to false imprisonment.
• The presence of lawful authority, such as reasonable grounds for arrest, prevents a claim of false imprisonment.
• For private prosecutors, the absence of reasonable and probable cause, when accompanied by indirect motive, may lead to liability for false imprisonment.
• The court specified that depositions under s.17 of the Indictable Offences Act 1848 must be correctly recorded, with each day's evidence clearly distinguished.

Legal Principles

• False imprisonment is actionable upon total deprivation of liberty, regardless of the claimant’s awareness of the restraint.
• Physical violence or direct physical detention is not required to constitute false imprisonment.
• Lawful authority, such as valid police powers, forms a defense to false imprisonment, but private prosecutors lack such privilege.
• Improper motive or absence of genuine belief in guilt may support claims against private parties for unlawful detention.
• Procedural integrity in witness depositions is essential for safeguarding the rights of the accused and ensuring transparency in judicial proceedings.

Conclusion

Meering v Graham-White Aviation Co Ltd clarified that total restraint constitutes false imprisonment even if the restrained person is unaware, distinguished lawful authority from private detentions, and emphasized procedural rigor in case documentation, thus shaping modern common law understanding of false imprisonment.