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

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.

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