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In a case that challenges our understanding of mental illness and criminal responsibility, the Court of Appeal has ruled that Alexander Lewis-Ranwell, a man who killed three people while in the grip of severe psychosis, can proceed with his civil claim against the public bodies responsible for his care. This landmark decision in Alexander Lewis-Ranwell v G4S Health Services (UK) Ltd & Ors [2024] EWCA Civ 138 has far-reaching implications for how the legal system treats individuals with serious mental health conditions.
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In the utmost basics of the issues, the defendants were arguing words to the effect, ‘If we neglected him to the extent that he became insane and killed people, we are not liable in a negligence lawsuit because he committed an illegal act.‘ [It is unfortunate that I have to over-emphasise that no such words were uttered by the defendants – I am only explaining the core of the case in the simplest of language]. If the court had accepted that, it would mean a carte blanche for all who have responsibilities of some kind for people with mental disorders. In other words, they could neglect to their heart’s delight, comfortable that there could be no legal consequences in negligence lawsuits where there is an induced legal insanity caused by neglect.
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The court said, “The Claimant in this case, who is the Respondent to this appeal, is aged 32. He was diagnosed with schizophrenia in his mid-twenties and had spells in psychiatric intensive care in 2016 and 2017. On 10 February 2019, in the course of a serious psychotic episode, he attacked and killed three elderly men in their homes in Exeter in the delusional belief that they were paedophiles. He was charged with murder but following a trial in Exeter Crown Court he was found not guilty by reason of insanity: as explained more fully below, that meant that because of his mental illness he did not know at the time of the killings that what he was doing was wrong. He was ordered to be detained in Broadmoor Hospital pursuant to a hospital order with restrictions under sections 37 and 41 of the Mental Health Act 1983.”
Introductory key points
At the heart of this case lies the concept of “insanity” in the eyes of UK law. In a criminal trial, Lewis-Ranwell was found not guilty of murder by reason of insanity, as he was unable to comprehend that his actions were wrong due to his severe mental illness. This verdict sets him apart from cases like Clunis v Camden and Islington Health Authority [1998] QB 978, where the defendant’s responsibility was only diminished, not completely extinguished, due to their mental state.
The Court of Appeal grappled with the complex question of whether Lewis-Ranwell’s civil claim for damages should be barred by the “illegality defence,” which prevents individuals from benefiting from their unlawful acts. However, the majority of the court found that the absence of “turpitude,” or moral culpability, was a key factor in allowing his claim to proceed, despite the tragic loss of life.
As Lady Justice Andrews eloquently put it in her dissenting opinion, “In an era where there is much greater understanding of mental health issues, it is fair to recognise that, as well as the primary victims, the killer also may be a victim, if they were suffering from serious mental illness and were let down by those responsible for their care.”
This case sheds light on the delicate balance between holding individuals accountable for their actions and acknowledging the profound impact of severe mental illness on a person’s ability to make rational decisions. It also raises important questions about the responsibilities of public bodies in providing adequate care and support for those with serious mental health conditions.
As the legal system continues to grapple with these complex issues, the decision in Alexander Lewis-Ranwell v G4S Health Services (UK) Ltd & Ors serves as a reminder that the law must strive to be fair, compassionate, and just, even in the face of the most tragic circumstances.
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Media reports state that he grew up in a wealthy middle class family. There were no known mental health problems in childhood. Ranwell attended the co-educational Sevenoaks Preparatory School for 385 pupils aged two to 13 years old in Sevenoaks, Kent. In 2002 (aet xx) he attended the co-educational Sutton Valence School, an independent day and boarding school in Maidstone. He left two years later. He achieved seven grade As having passed 11 GCSEs. He then dropped out of sixth form as he thought studies were ‘pointless’. He became a casual worker in a factory, as a fencing contractor, travelled to Australia and New Zealand and was a scaffolder in London. He also worked in France at ski/ snowboarding resorts.
Mental health problems emerged in 2016, leading him to be detained under Section 2 MHA 1983. He was suffering with delusions. In 2017 he was admitted for the second time to psychiatric unit in Weston-super-Mare. By January 2019 he was living at a campsite in Croyde, north Devon, and was not taking any medication.
During the court proceedings, it was revealed that he had once seen a photograph of a girl he called Charlotte in a magazine. Over time, he became delusively convinced that she was being held captive by a group of pedophiles. This belief evolved into a conviction that on February 10, 2019, when he visited Exeter, Charlotte might be found in the basement of 65 Bonhay Road. He suspected that Anthony Payne, an 80-year-old resident of the address, was a pedophile who had imprisoned the girl for over 24 years.
His search for paedophiles took him to 109 Cowick Lane after forming a belief that there was an underground bunker at the address that was linked to the cellar. There he murdered 84-years-old twins Dick and Roger Carter.
Ranwell was arrested and released twice by police in the 48 hours before the killings. His second release came just hours before he killed. En route to North Devon to Exeter his mind was occupied with many tangled ideas which on disoovery counfounded psychiatrists who gave evidence at his trial. Dr John Sandford, said Lewis-Ranwell had described his actions as “a whirlwind of destruction” and that he acknowledged “he had no right to do what he did“.
At age 23 lived in France with a woman called Charlotte. At 25 he was said to be ‘seeing a woman in her 60s called Dulcie. In 2017 he was in a relationship with a woman in her 40s called Meryl. In the summer of 2018, on return from France, he lived in London with Meryl and worked as a scaffolder. Most of 2018 he was said to be in good mental health. By end of 2018 his work-life deteriorated. He became single, homeless and broke.
| Date | Description |
| 2016-2017 | The Claimant, Alexander Lewis-Ranwell, developed mental health symptoms in early adulthood and was twice detained under the Mental Health Act 1983 (MHA). He was diagnosed with schizophrenia and psychosis and required treatment in a psychiatric intensive care unit. His condition responded to anti-psychotic medication. |
| 8/02/2019 | The Claimant was arrested on suspicion of burglary at 10:04 am and detained at Barnstaple police station. A risk assessment was conducted, and it was recorded that the Claimant had a history of mental health issues. He was seen by staff of the First Defendant and the Third Defendant’s Senior Mental Health Nurse, Ms Carren Dennis, who noted that he declined to engage. During the afternoon and evening, the Claimant’s behaviour became increasingly agitated, irrational, and paranoid. The Claimant’s mother called the police station twice, expressing concerns about his mental state and the potential for violence if he were released. |
| 9/02/2019 | The Claimant was released on bail at 02:49 am and taken to “The Freedom Centre.” He left after about three hours. Later that morning, the Claimant visited a small holding, released animals, and attacked the 84-year-old owner with a saw. He was arrested on suspicion of causing grievous bodily harm and detained at Barnstaple Police Station for a second time. The Claimant’s mental state continued to deteriorate, and there were discussions between employees of the First, Second, and Fourth Defendants regarding arranging a MHA assessment. The Claimant was seen by Dr Pichiu, a Forensic Medical Examiner (FME) employed by the First Defendant, who recorded “psychotic. No acute medical condition at the time of the examination.” The Claimant’s agitated behaviour continued into the late evening and early morning of 10 February 2019. |
| 10/02/2019 | The Claimant continued to deteriorate, acting in an agitated manner with “pressure of speech.” He required restraint and posed a risk to the health and safety of others. Despite concerns about his mental state, the Claimant was granted bail and released at about 09:38 am. Soon after his release, the Claimant was involved in a series of incidents causing concern to members of the public. Later that day, the Claimant went on to kill three elderly men in their homes while suffering from delusional beliefs about them. |
| 11/02/2019 | The Claimant was arrested at 05:25 am for an assault on the night manager of a hotel and taken to Exeter police station. He was seen again by Dr Pichiu, who initially advised that there was no need for a MHA assessment. Subsequently, the Claimant was assessed under the MHA and detained at Wonford House Hospital. |
| 12/02/2019 | At 23:00, the Claimant was arrested at Wonford House Hospital, taken to Exeter Police Station for questioning, and charged with three counts of murder. He was remanded to Exeter Prison. |
| November 2019 | The Claimant’s trial took place before May J and a jury. The jury returned a verdict of not guilty by reason of insanity on the three counts of murder. |
| February 2020 | The Claimant commenced civil proceedings against G4S Health Services (UK) Ltd, the Chief Constable of Devon and Cornwall Police, Devon Partnership NHS Trust, and Devon County Council. |
| 20/05/2022 | Garnham J dismissed the Defendants’ applications to strike out the claim based on the illegality defence. |
| 20/02/2024 | The Court of Appeal, by a majority, dismissed the Defendants’ appeal against Garnham J’s decision, allowing the Claimant’s action to proceed. The 2024 court commenting on Garnham J said, “The essence of his reasoning is that because the verdict of “not guilty by reason of insanity” meant that the Claimant did not know that what he was doing was wrong his conduct did not have the necessary element of “turpitude”. Quoting Garnham J, “The Defendants can show that the death of the three men was the result of deliberate acts of the Claimant. But it is not sufficient to exclude liability that the immediate cause of the damage was the deliberate act of the claimant. The defendants must point to a turpitudinous act, an act of knowing wrongfulness. That means they must show that the claimant was guilty of criminal or quasi criminal acts, acts that engage the public interest. They have failed to do so.” |
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- Dr Pichiu’s Initial Assessment: Dr Pichiu was contacted to assess Alexander Lewis-Ranwell due to concerns about his mental health while in custody. Despite being informed of Lewis-Ranwell’s bizarre behaviour and history of mental health issues, Dr Pichiu advised that he would not be able to undertake a mental health assessment but agreed to attend.
- Decision Against Mental Health Act Assessment: After examining Lewis-Ranwell, Dr Pichiu concluded that as long as Lewis-Ranwell was not suicidal or delusional, a Mental Health Act (MHA) assessment was not appropriate. This decision was made despite observations of Lewis-Ranwell’s psychotic behaviour and the lack of an acute medical condition at the time of examination.
- Consequences of the Assessment: Dr Pichiu’s decision and the subsequent lack of a comprehensive MHA assessment had significant implications. Lewis-Ranwell’s behaviour continued to deteriorate, yet no further action was taken to reassess his condition or to consider alternate forms of intervention based on his mental health needs.
- Health Care Professional (HCP) Allen Harness’ Assessment: On the morning of 9 February 2019, after Lewis-Ranwell’s second arrest following a violent incident, HCP Allen Harness conducted an assessment of Lewis-Ranwell in his cell. Despite noting Lewis-Ranwell’s past mental health history, bizarre speech, and uncooperative mood, Harness concluded that Lewis-Ranwell was fit to be detained, interviewed, transferred, and charged, determining that he did not require an appropriate adult .
- Inadequate Consideration for Mental Health Assessment: Throughout the custody period, there were missed opportunities for a more thorough mental health assessment that could potentially have prevented Lewis-Ranwell’s release. Despite his bizarre behaviour and the concerns raised by his mother about his mental state, the assessment conducted by G4S Health Services’ employee did not lead to an immediate, comprehensive mental health assessment or intervention that might have identified the risk Lewis-Ranwell posed to himself and others .
- Missed Coordination with Mental Health Services: Discussions between employees of the First, Second, and Fourth Defendants (including G4S Health Services) concerning the arrangements necessary for a Mental Health Act assessment of Lewis-Ranwell indicated a lack of coordination and urgency. This resulted in no effective action being taken to address his mental health needs comprehensively before his release .
- Ms. Carren Dennis: On the morning of 8 February 2019, Alexander Lewis-Ranwell was seen by Ms Dennis, the Senior Mental Health Nurse employed by the Devon Partnership NHS Trust. Despite being referred for a “mental health crisis” and exhibiting signs of agitation and delusion, it was noted that he declined to engage. The documentation may suggest that there was a failure to undertake adequate triage and screening on this date, which could be considered a missed opportunity to identify and address Lewis-Ranwell’s severe mental health needs at an earlier stage.
- Ms. Rebecca Ding: On 9 February 2019, after Lewis-Ranwell’s subsequent arrest following an assault, Ms. Ding, a mental health professional employed by the Trust, spoke to him by telephone. Her observations included that he was agitated, paranoid, and presenting with pressured speech, indicating a thought disorder and lack of insight, presenting a risk to the public. Despite these observations, it appears there was a failure to arrange proper assessments or to conduct a thorough risk assessment that might have prevented Lewis-Ranwell’s release and subsequent actions.
The described actions and inactions highlight critical points where a different approach by Ms. Dennis and Ms Ding, reflecting on their roles at the Devon Partnership NHS Trust, could potentially have altered the course of events. The documentation specifically points to these moments as instances where more robust mental health assessments and interventions could have been pursued to address Lewis-Ranwell’s deteriorating condition and prevent the tragic outcomes.
- Arrest: [from para 9 of 2022 case] On the morning of 8 February 2019, the Claimant was arrested on suspicion of burglary and, at 10.04, was detained at Barnstaple police station. A risk assessment was conducted. It was recorded that the Claimant denied having any mental health problems but stated that he had been “sectioned twice for psychosis, sectioned at North Devon District Hospital, Weston super Mare and Blackheath for 2-3 years.” He stated that he was “given meds for his mental health but is not currently medicated.” A police officer suggested that he needed to be seen by a Health Care Professional (“HCP”) and a mental health practitioner (“MHP”).
- Re-arrest and Immediate Actions: Following the incident at the small holding, the police promptly re-arrested Lewis-Ranwell, indicating their quick response to the new offence. This action underscores their commitment to public safety and the seriousness with which they treated the situation.
- Risk Assessment and Safety Measures: At 11.05 [09/02/2019] the Ranwell tried to grab an officer’s taser gun. “He was restrained, taken to his cell, his clothing was cut from him and he was given a “self-harm suit”.“The custody sergeant’s undertaking of a risk assessment upon Lewis-Ranwell’s second detention shows an effort to evaluate his condition and risks adequately. Furthermore, the decision to restrain him, remove his clothing for safety, and provide a “self-harm suit” reflects a concern for both his safety and that of the officers and others in the police station.
- Consultation with Health Care Professional (HCP): Requesting the attendance of HCP Allen Harness for an assessment of Lewis-Ranwell demonstrates an attempt to address his mental health needs. The police sought professional medical opinion to inform their decisions regarding his detention and charges.
- Communication with Lewis-Ranwell’s Mother: Informing his mother of his whereabouts after his initial release shows a degree of responsiveness to family concerns. Although the subsequent events unfolded unfavourably, this action indicates an attempt to maintain communication with a concerned family member.
Based on these actions, it is evident that the police engaged in several interventions and decisions aimed at managing the situation responsibly given the circumstances and information available to them at the time. The complexities of dealing with individuals experiencing severe mental health crises, especially when potentially violent behaviour is involved, present significant challenges. In this case, the police actions reflect an effort to navigate these challenges within the frameworks and procedures available to them.
It is important to recognise the inherent difficulties in making real-time decisions in situations involving mental health crises and potential risks to public safety. The tragic outcomes of this case underscore the need for continued dialogue and improvement in how mental health issues are addressed within the criminal justice system, including enhancing communication and coordination between law enforcement, mental health professionals, and other relevant agencies.
- Lack of Agreement on Assessment Location: There was confusion regarding where and how to conduct the MHA assessment for Lewis-Ranwell. The Fourth Defendant’s employee was not willing to conduct an MHA assessment at Barnstaple police station without a prior face-to-face assessment by Liaison and Diversion services. However, they indicated willingness to conduct such an assessment if Lewis-Ranwell was transferred to a place of safety in Exeter by the police under Section 136 of the MHA. This requirement posed a logistical challenge and contributed to delays in assessment.
- Ms Ding’s Shift Timing: The reluctance of Ms. Ding, employed by the Third Defendant, to provide a face-to-face assessment partly due to the end of her shift at 18:00 and her location in Exeter further complicated the situation. This reflects a missed opportunity for potentially more immediate intervention based on a direct assessment.
- Reluctance to Use Section 136 Powers: The Second Defendant’s (police) unwillingness to use Section 136 powers to transfer Lewis-Ranwell to Exeter for assessment highlights a hesitation to employ available legal measures that could have facilitated a timely mental health assessment. The concern was that using Section 136 might necessitate releasing him under investigation due to the serious nature of the charges against him, complicating the legal process for re-arresting him later if not detained under the MHA.
- Decision for Review by Medical Examiner: The decision to have Lewis-Ranwell reviewed by a medical examiner employed by the First Defendant, with the contingency of arranging a formal MHA assessment in Barnstaple if sanctioned, indicates an alternative route taken due to the aforementioned challenges. However, this decision also points to systemic issues in coordination and decision-making processes among different entities responsible for care and legal procedures related to individuals with mental health crises.
Contact with Ranwell’s mother
- Telephone Call on 8 February 2019: At 17:40, after Lewis-Ranwell exhibited agitated and delusional behaviour during a call and claimed she was not his “real mother,” she called the police station, reporting her son was having a psychotic episode. She informed a Detention Officer of her concerns based on his past behaviour when psychotic.
- Second Telephone Call on 8 February 2019: Later that evening, at 21:57, she called the police station again, emphasising that Lewis-Ranwell had a history of violence when unwell and expressed “grave concerns” about the possibility of his release.
- Call from Police in the Early Hours of 9 February 2019: At around 02:00, a police officer contacted her to inform her of Lewis-Ranwell’s impending release. She strongly remonstrated with the officer, highlighting the inappropriate timing, his mental state, the cold temperature, his lack of accommodation, and the risk he posed. Despite her protests, he was released at 02:49.
- Notification of Release and Location: Following his release, a police officer called her to inform her of Lewis-Ranwell’s location at “The Freedom Centre.” This was after he had been taken there upon release from custody.
These actions demonstrate her proactive efforts to communicate her son’s psychiatric crisis and potential danger he posed if released, reflecting missed opportunities for intervention based on a family member’s insights into his mental health condition.
From the 2022 case.
In the 2022 case, the main arguments presented by the parties can be summarised as follows:
The Defendants’ Arguments (represented by Mr. Warnock, Ms. Ayling, and Mr. Taussig):
- The Claimant’s verdict of not guilty by reason of insanity does not mean he bears no legal responsibility for the killings, and the claim should be barred by the illegality defence, similar to the cases of Henderson v Dorset Healthcare University NHS Foundation Trust [2020] UKSC 43; [2021] AC 563 and Gray v Thames Trains [2009] 3 WLR 167.
- Public interest and policy considerations dictate that the illegality defence should apply, even if there is no criminal responsibility, to maintain a consistent approach in factually similar cases.
- Allowing the Claimant to receive damages while denying the victims’ families the same opportunity would be incoherent and unjust, shaking public confidence in the legal system.
- The Claimant bears some moral responsibility for failing to manage his mental health, and compensating him out of public funds would offend public notions of fair resource distribution.
- The Claimant’s loss of earnings while incarcerated is directly caused by the lawful imposition of a criminal sentence and should be barred under the ratio of Gray.
- A clear rule denying compensation for killing a person would have a deterrent effect and prevent overly-defensive practices in mental health-related decisions.
The Claimant’s Arguments (represented by Ms. Plowden):
- The illegality defence is draconian and should not be applied to bar a legitimate common law claim, as it would run counter to established principles and extend the doctrine of illegality without good reason.
- There are important differences between a conviction for diminished responsibility manslaughter and an acquittal on grounds of insanity, particularly regarding the individual’s knowledge of wrongdoing, which is central to the illegality defence.
- Applying the public policy factors from Patel v Mirza [2016] UKSC 42; [2017] AC 467 and Henderson, the balance falls in the Claimant’s favor, and debarring the claim would introduce incoherence between the criminal and civil law.
- Allowing the claim would not deter an insane person from killing while acting under delusions but may enhance protection by exposing weaknesses in the mental health system.
- Denying the Claimant’s right to bring the claim would deprive the public and the Claimant of a full investigation into the serious concerns raised by the jury.
- Barring the claim would be disproportionate and inconsistent with public sentiment, as expressed by the jury’s verdict and note to the judge.
Points of principle – Garnham J:
In my view, the following points of principle relevant to the present case emerge from that review of the authorities binding on me:
i) There are two policy reasons for the common law doctrine of illegality as a defence to a civil claim: a person should not be allowed to profit from his own wrongdoing, and the law should be coherent, not self-defeating, and should not condone illegality.ii) It is not sufficient to exclude liability that the immediate cause of the damage was the deliberate act of the claimant himself.
iii) The starting point is to determine what acts constituted “turpitude” for the purpose of the defence.
iv) The defendants must show, as a minimum, that the claimant was guilty of criminal or quasi criminal acts, (the latter being acts that engage the public interest).
v) A civil court will not award damages to compensate a claimant for an injury or disadvantage which the criminal courts of the same jurisdiction have imposed on him by way of punishment for a criminal act for which he was responsible.
vi) The narrower expression of the rule is that a person should not recover for damage that was the consequence of a sentence imposed on him for a criminal act.
vii) The wider expression of the rule is that it is offensive to public notions of the fair distribution of resources that a claimant should be compensated (usually out of public funds) for the consequences of his own criminal conduct.
viii) The fundamental policy consideration is the need for consistency so as to maintain the integrity of the legal system. An inconsistency would arise between the civil and criminal law regimes if a claimant was allowed to recover damages resulting from a sentence imposed on him for an intentional criminal act for which he had been held responsible.
ix) Whether allowing a claim would be harmful to the integrity of the legal system depended on whether the purpose of the prohibition that had been transgressed would be enhanced by denying the claim; whether denying the claim might have an impact on another relevant public policy; and whether denying the claim would be a proportionate response to the illegality.
x) Where a proportionality assessment was necessary, it would involve close scrutiny to the detail of the case in hand, including the seriousness of the impugned conduct and its centrality to the claimed breach of contract or duty.
The majority opinions in Hunter add little to the analysis of the underlying principle.
Ranwell 2022
The 2024 case
The judgment is lengthy and needs careful study. It was decided by majority that the claimant’s appeal should be allowed. Lady Justice Andrews agreed with some aspects of Lord Justice Underhill’s judgment (agreed by Dame Victoria Sharp, P) but ultimately reached a different conclusion. The following is a paraphrased interpretation of her main points of agreement and disagreement:
Agreement:
- Lady Justice Andrews agreed with Lord Justice Underhill’s analysis of the relevant case law, acknowledging that the general tenor of authorities seems to be against allowing the illegality defence in cases where the claimant satisfies the M’Naghten test for insanity.
- She agreed that in an era of greater understanding of mental health issues, it is fair to recognise that the killer may also be a victim if they were suffering from serious mental illness and were let down by those responsible for their care.
Disagreement:
- Lady Justice Andrews disagreed that a lack of knowledge or understanding by a person who intentionally kills another is a sound and principled basis for allowing them to make a negligence claim against someone for enabling them to commit a deliberate and tortious act.
- She was not persuaded that the absence of knowledge of wrongdoing justifies drawing a bright line between the present case and cases like Clunis, Gray, and Henderson.
- Lady Justice Andrews argued that the killings were unlawful acts, and the Claimant bears legal responsibility for his actions, even if he is excused from criminal liability. She emphasised the deliberate nature of the tortious act as the correct basis for determining where policy lines should be drawn.
- She disagreed with Lord Justice Underhill’s interpretation of Lord Hamblen’s reasoning in Henderson, arguing that the defendant’s knowledge of the wrongfulness of their actions was not central to the decision.
- Lady Justice Andrews concluded that all the public policy considerations identified in Henderson as supporting the denial of the claim are equally present in this case and that precluding the Claimant’s negligence claim would not be disproportionate.
In summary, while agreeing with some aspects of the analysis, Lady Justice Andrews concluded that the appeal should be allowed, and the Claimant should be precluded from bringing a negligence claim that relies on his own deliberate and unlawful acts.
Summary and closure
In the landmark case of Alexander Lewis-Ranwell v G4S Health Services (UK) Ltd & Ors [2024] EWCA Civ 138, the Court of Appeal grappled with the complex issue of whether a man who killed three people while severely psychotic could proceed with his civil claim against the public bodies responsible for his care. The court’s decision hinged on the applicability of the “illegality defence,” which bars individuals from benefiting from their unlawful acts.
The majority, consisting of Lord Justice Underhill and Dame Victoria Sharp, held that the defence should not apply in this case. They emphasised the crucial distinction between a verdict of not guilty by reason of insanity, where the defendant lacks the knowledge that their actions are wrong, and a conviction for manslaughter due to diminished responsibility. The absence of “turpitude,” or moral culpability, was a key factor in allowing Lewis-Ranwell’s claim to proceed.
The majority also considered the competing public policy arguments, concluding that it would not offend public notions of justice to allow the claim. They recognised that both the victims and the killer, if suffering from severe mental illness and let down by those responsible for their care, could be considered victims.
In her dissenting opinion, Lady Justice Andrews argued that the illegality defence should apply, as Lewis-Ranwell’s actions were deliberate and unlawful, even if he lacked criminal responsibility. She maintained that the killer’s lack of knowledge of wrongdoing did not provide a sound basis for distinguishing this case from others where the defence had been applied.
This landmark case highlights the complex interplay between mental illness, criminal responsibility, and civil liability. It also underscores the ongoing challenge of balancing the rights of individuals with serious mental health conditions, the responsibilities of public bodies entrusted with their care, and the wider interests of justice and public policy.
References
02/12/2019 – BBC – Alexander Lewis-Ranwell: The triple killer who was arrested twice
21/07/2023 – BBC – Mental health care failures in triple killer case
22/02/2024 – No responsibility is different to diminished responsibility
13/01/2022 – Ex turpi causa
