Alexander Lewis-Ranwell v G4S Health Services (UK) Limited & Ors

Alexander Lewis-Ranwell v G4S Health Services (UK) Limited & Ors

The doctrine of illegality (ex turpi causa) does not bar a civil claim for negligence where the claimant was found not guilty by reason of insanity, as such a verdict is a finding of no criminal responsibility and the claimant did not know his acts were wrong. The defendants failed to establish that the claim was based on a criminal or quasi-criminal act for which the claimant bore responsibility. Therefore, the applications to strike out the claim must fail.

Parties
Claimant: Alexander Lewis-Ranwell; First Defendant: G4S Health Services (UK) Limited; Second Defendant: Chief Constable of Devon and Cornwall Police; Third Defendant: Devon Partnership NHS Trust; Fourth Defendant: Devon County Council
Jurisdiction
England and Wales
Judgment Date
20 May 2022
Procedural Posture
Civil / Application to Strike Out Claim (preliminary Issue)
Outcome
Applications to strike out the claim on grounds of illegality dismissed.
Legal Topics
Illegality Defence (ex Turpi Causa), Negligence, Insanity Defence, Public Policy, Causation
Tort Law Mental Health Law Civil Procedure Illegality Defence (ex Turpi Causa) Negligence Insanity Defence Public Policy Causation

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 23 Party arguments 2
Sign in to unlock

Parties

Alexander Lewis-Ranwell

Claimant

G4S Health Services (UK) Limited

First Defendant

Chief Constable of Devon and Cornwall Police

Second Defendant

Devon Partnership NHS Trust

Third Defendant

Devon County Council

Fourth Defendant

Procedural Posture

Civil / Application to Strike Out Claim (preliminary Issue)

Legal Issues

  1. 1 Does the doctrine of illegality (ex turpi causa) bar a civil claim for negligence where the claimant was found not guilty by reason of insanity for killings forming the factual basis of the claim?
  2. 2 Is a verdict of not guilty by reason of insanity equivalent to a finding of no criminal responsibility for the purposes of the illegality defence in tort?

Ratio Decidendi

The doctrine of illegality (ex turpi causa) does not bar a civil claim for negligence where the claimant was found not guilty by reason of insanity, as such a verdict is a finding of no criminal responsibility and the claimant did not know his acts were wrong. The defendants failed to establish that the claim was based on a criminal or quasi-criminal act for which the claimant bore responsibility. Therefore, the applications to strike out the claim must fail.

Court Disposition

Applications to strike out the claim on grounds of illegality dismissed.

Orders

  • The applications by the First, Third, and Fourth Defendants to strike out the claim are refused.