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Study Notes

Key Case | Hill v Chief Constable of West Yorkshire Police (1989) | Negligence - Duty of Care & Proximity

A Level, BTEC Level 3
AQA, Edexcel, OCR, IB, Eduqas, WJEC

This case established that no duty of care is owed in negligence if there is no proximity between the defendant and particular claimant.


Claimant: Mrs Hill – mother of deceased victim of the Yorkshire Ripper

Defendant: West Yorkshire Police

Facts: Peter Sutcliffe, the ‘Yorkshire Ripper’ conducted 13 murders and 8 attempted murders that are known. This case was brought against the Police in negligence by the mother of his last victim, Jacqueline Hill, upon the grounds that the Police were negligent by failing to apprehend Sutcliffe, if they had done her daughter’s murder could have been prevented.

Outcome: Not Liable

Legal principle: There is no duty of care on the police to apprehend unidentified criminals and therefore they are consequently not liable in negligence where these criminals commit further crime. Whilst it was certainly foreseeable that an individual like the claimant may be harmed, there was no proximity between the Police and the particular victim, she was simply one of a large category of possible victims. Jacqueline Hill was at no particular distinctive risk and thus no duty could be imposed due to lack of proximity via relationship.

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