## Facts

- Martin Lynch was detained in police custody, where he was known to be at risk of self-harm due to previous suicide attempts and mental health issues.
- Despite this known risk, police failed to take adequate precautions, such as removing Lynch's belt.
- Lynch used his belt to hang himself and died while in police custody.
- Reeves, acting as the administratrix of Lynch’s estate, sued the Commissioner of Police for the Metropolis alleging negligence and breach of duty of care.

## Issues

1. Whether the police owed a duty of care to Lynch to prevent self-harm while he was in custody.
2. Whether Lynch’s suicide constituted a novus actus interveniens, breaking the chain of causation and absolving the police of liability.
3. Whether the damages should be reduced due to contributory negligence by Lynch.

## Decision

- The police were found to owe a duty of care to detainees, including an obligation to prevent foreseeable self-harm.
- The House of Lords held that Lynch’s suicide did not break the chain of causation, as it was a foreseeable outcome of the police’s breach.
- The court applied the Law Reform (Contributory Negligence) Act 1945 and recognized contributory negligence but did not reduce damages significantly, emphasizing the police's primary responsibility.
- The act of suicide by Lynch was deemed within the scope of the risk that the police were required to guard against.

## Legal Principles

- Public authorities, such as the police, owe an enhanced duty of care to individuals in custody, which includes preventing foreseeable self-inflicted harm.
- A voluntary act by the claimant does not break the chain of causation if it is within the scope of the risk created by the defendant’s negligence.
- The doctrine of novus actus interveniens is limited where the defendant's duty specifically encompasses the risk that materializes.
- Damages in negligence can be apportioned under the Law Reform (Contributory Negligence) Act 1945, but the primary liability rests with the authority where breach is the principal cause.

## Conclusion

The House of Lords established that police must take reasonable steps to prevent detainees from self-harm, and a detainee’s suicide does not sever causation if arising from a breach of that duty; contributory negligence may be considered, but significant liability remains with the custodial authority.


Reeves v Commissioner of Police for the Metropolis [2000] 1 AC 360