Reeves v Metropolitan Police Commissioner [2000] AC 360

Facts

  • Martin Lynch was a detainee held in police custody by the Metropolitan Police.
  • Lynch committed suicide while in custody.
  • The claimant (Reeves) alleged that the police breached their duty of care by failing to prevent Lynch’s suicide, despite knowledge of his suicidal tendencies.
  • The Metropolitan Police sought to rely on the volenti non fit injuria defence, arguing that Lynch had voluntarily assumed the risk of self-harm.
  • The House of Lords ruled in favor of the claimant, determining that the police’s protective duty took precedence over the volenti defence.

Issues

  1. Whether the Metropolitan Police could rely on the volenti non fit injuria defence to avoid liability for the suicide of a detainee in their custody.
  2. Whether the police’s protective duty to detainees overrides the volenti defence.
  3. The extent to which foreseeability of self-harm establishes the duty of care.
  4. How contributory negligence applies when a detainee’s actions contribute to their own harm.

Decision

  • The House of Lords held that the volenti defence does not apply where the defendant owes a protective duty, such as preventing a detainee’s suicide.
  • The police owed a duty to take reasonable steps to prevent foreseeable self-harm or suicide by detainees.
  • The breach of this duty by the police was a direct cause of Lynch’s death.
  • Damages were reduced to reflect contributory negligence, as Lynch’s actions had contributed to his own harm.

Legal Principles

  • The volenti non fit injuria defence is inapplicable when the defendant owes a protective duty, especially in custodial contexts.
  • Custodial authorities are required to protect detainees from foreseeable risks, including self-harm.
  • Causation is established if failure to uphold the protective duty leads directly to harm, but damages may be reduced for contributory negligence.
  • The judgment reaffirms that the existence of a special relationship (such as custody) imposes a higher standard of care compared to ordinary negligence cases.

Conclusion

The House of Lords clarified that where a custodial protective duty exists, such as with police and detainees, the volenti defence cannot absolve authorities from liability for foreseeable self-harm. This decision reinforced the requirement for custodial authorities to take reasonable precautions to prevent suicide, while allowing for reductions in damages due to contributory negligence.

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