Wimblett v Chief Constable of Lancashire [2026] EWHC 1586 (KB) (judgment here)

When should a briefing officer be held liable in false imprisonment for giving mistaken information to the arresting officer? Is the position different if the briefing officer is dishonest in the information s/he provides? These are questions answered by the recent case of Wimblett.

The background

The Claimant’s former wife obtained a non-molestation order (NMO) against him. Thereafter, allegations were made to Lancashire police which, if true, meant that the Claimant was in breach of the NMO. PC Wade was assigned to the case. Following investigations, PC Wade learnt that the Claimant had moved to Devon.

PC Wade issued a Police National Computer Nominal (PNCN) marked as “Wanted Report with Power of Arrest”. This was effectively a “wanted” notice whereby the Claimant’s name was added to the PNC together with a brief outline of the circumstances and reasons why he was wanted. PC Wade explained in his witness statement that the PNCN meant “an arrest would be affected [sic] based on the circumstances I had provided in the Circulation Form” although he also explained that it would be for the actual arresting officer to determine when the time came whether there was in fact any necessity to arrest.

A short time after the PNCN was issued, the Claimant attended Torquay Police Station where he was arrested by PC Edmunds of the Devon and Cornwall Police. The Claimant was interviewed and then released. In the event, no further action was taken against him.

The Claimant brought a claim against Lancashire Police only, on the basis it had directly procured his wrongful arrest by circulating the PNCN. The Judge directed that, “The issue of vicarious liability shall be addressed as a preliminary issue.” It was agreed that vicarious liability was not the correct phrase; what was in issue was whether PC Wade had “procured” the arrest as an example of accessory liability.

At first instance, the Judge held that it could not be established that PC Wade was effectively the arresting officer and accordingly dismissed the claim in so far as brought on the basis of accessory liability. The Claimant appealed, contending that the Judge had failed to apply the law on accessory liability as set out by the Supreme Court in Lifestyle Equities CV v Ahmed (‘Lifestyle’ [2024] UKSC 17).

R (Przybys) v Chief Constable of Greater Manchester Police [2026] EWHC 1159 (Admin) 15 May 2026 (judgment here)

This Administrative Court decision reviews the interrelationship between police investigations, regulatory processes and coronial decision-making.  Although the Senior Coroner for Manchester City was not a party to these proceedings, the court identified the coroner’s earlier assessment of this being a natural death that did not require an inquest, as a factor which Greater Manchester Police (‘GMP’) was entitled to take into account when deciding not to launch a criminal investigation into alleged gross negligence manslaughter.

R (Rizvi) v HM Assistant Coroner for South London [2025] EWHC 3014 (Admin) judgment 17^th Nov 2025 here

It has been a long journey for Mrs Rizvi who may now have exhausted all avenues in her attempts to show that the police breached an Article 2 duty owed to her daughter.  Twelve and a half years ago Sabina Rivzi was the innocent victim of a gang shooting as she drove away from Bexleyheath Police Station, having picked up her boyfriend after a police interview.  A High Court judge has now forcefully concluded that, having held an Article 2 compliant investigation and inquest, the Assistant Coroner[1] was entitled to consider it unsafe to leave any findings of fact to the jury regarding acts or omissions by the police. The Claimant’s counsel’s “island-hopping expedition in a sea of extensive evidence” did not persuade Mr Justice Foxton that it was arguable that the Coroner’s assessment that it would be unsafe to do so had been unreasonable in the Wednesbury sense.

This case importantly delineates the ambit of the Article 2 procedural duty on coroners. It is exactly what it says on the label – a duty of procedure and not one of outcome. It is quite a low threshold that triggers the procedural duty [2] to investigate an arguable Article 2 breach. But the hurdle to be surmounted before making any positive finding is somewhat higher once the evidence has been heard. In many cases a thorough exploration of all the evidence will reveal there is no state shortcoming that needs to be left to the jury, let alone reflected in the inquest’s conclusion.

In the matter of an application by the Secretary of State for Northern Ireland for Judicial Review (Appellant) [2025] UKSC 47 here

At approximately 11.15pm on 27 April 1994, 25-year-old Liam Paul Thompson was shot and killed near a gap in a peace line separating nationalist and unionist neighbourhoods in Belfast. No one has ever been held accountable for his death.

Indeed, in the context of what the Supreme Court describe as “egregious and profoundly disturbing delays” there has still not been an effective and Article 2 compliant investigation into Mr Thompson’s death.

The abortive inquest that was commenced in 2023 has, however, given the Supreme Court cause to answer an important question of principle: What test, and what level of scrutiny, should be applied by a court reviewing a decision to disclose material over which a claim of Public Interest Immunity (‘PII’) has been made?

In a unanimous judgment, overturning the decisions of the Coroner, a High Court Judge, and two Court of Appeal judges, the Supreme Court affirms that the question whether evidence is covered by PII is a substantive question of the law of evidence, not an exercise of judicial discretion. A first instance court must determine where the overall public interest lies, by conducting the balancing exercise set out in R v Chief Constable of West Midlands Police, Ex p Wiley [1995] 1 AC 274.  The inquisitorial nature of an inquest will raise the stakes in PII cases as compared to civil litigation. If the first instance court misidentifies the public interest, it has gone wrong in law and an appellate or reviewing court is required to consider the balancing exercise itself and correct the error.

The County Court has dismissed a claim for misfeasance in public office and vicarious liability brought against the Chief Constable of Nottinghamshire Police, arising from the actions of a former police constable, Craig Stant.

The Claimant, Ms A, alleged that while off duty the officer had pursued an inappropriate and coercive relationship with her after stopping her car and identifying himself as a police officer. She claimed that in doing so the officer was purporting to act in the course of his public duties and that the Chief Constable was therefore vicariously liable for his actions. The Chief Constable had dismissed the officer because of his actions towards Ms A. Damages were sought for misfeasance, personal injury, and aggravated and exemplary damages.