Hill v Chief Constable of West Yorkshire [1989] AC 53 (HL)

Facts

Jacqueline Hill was the last known victim of the Yorkshire Ripper, Peter Sutcliffe. Her mother sued the police, claiming negligent investigation and delays in catching the killer had led to her daughter’s murder.

The case raised questions about whether police owe a duty of care to individual members of the public for failures to prevent crimes.

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Issue

Did the police owe a duty of care to individual members of the public in the investigation of criminal activity?

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Decision

The House of Lords held that the police did not owe a duty of care to individual victims in these circumstances. Imposing such a duty would be unfair and unworkable, and there was insufficient proximity between the police and the victim.

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Legal Principle

Public authorities are generally immune from negligence claims for omissions where harm arises from the acts of third parties. Duty is not owed when policy considerations outweigh individual claims.

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Importance

• Establishes limits of duty for public authorities.

• Important for “fair, just and reasonable” considerations under Caparo.

• Later refined by Robinson to clarify positive acts vs omissions.