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Orange v Chief Constable of West Yorkshire Police, Court of Appeal

8 May 2001
The issues

Police – Failure To Take Reasonable Steps To Prevent Suicide Of Prisoner In Police Custody

The facts

The widow and PR of Paul Orange sued the Chief Constable of the West Yorkshire Police following his suicide in a police cell. He was not a known suicide risk.

The decision

1. A custodian owed a duty to take reasonable care for the health and safety of the person in custody.

2. There was an increased risk of suicide amongst prisoners.

3. That did not mean that suicide was a foreseeable risk in relation to every prisoner.

4. It was neither fair, just or reasonable to impose on the police a general obligation to treat every prisoner as a suicide risk.

5. The generally increased risk of suicide amongst prisoners oblige the custodian to identify whether or not a prisoner presented a suicide risk.

6. The obligation to take reasonable care to prevent a prisoner from taking his own life deliberately only arose when the custodian knew or ought to have known that an individual prisoner presented a suicide risk. On the facts the deceased was not a person to whom the police officers owed a duty of care to prevent him from taking his life deliberately.

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The content on this page is provided for the purposes of general interest and information. It contains only brief summaries of aspects of the subject matter and does not provide comprehensive statements of the law. It does not constitute legal advice and does not provide a substitute for it.

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