Prepared for Unknown User. © ICLR 2026

Lewis-Ranwell v G4S Health Services (UK) Ltd

Hearings

England & Wales

20 May 2022 [2022] EWHC 1213 (QB); [2023] QB 229; [2022] 3 WLR 677; [2023] 2 All ER 254; [2022] WLR(D) 227, QBD (Garnham J)

20 Feb 2024 [2024] EWCA Civ 138; [2024] KB 745; [2024] 2 WLR 1377; [2024] 3 All ER 833; [2024] WLR(D) 78, CA (Dame Victoria Sharp P, Underhill, Andrews LJJ)

23 May 2024 (appn all) [2024] 1 WLR 2775, SC(E) (Lord Reed PSC, Lord Hamblen, Lord Richards JJSC)

United Kingdom

21 Jan 2026 [2026] UKSC 2; [2026] WLR(D) 46, SC(E) (Lord Reed PSC, Lord Lloyd-Jones, Lady Rose, Lady Simler JJSC, Lord Hodge)

Subject Matter

PUBLIC POLICY — Illegality — Civil claim — Claimant tried for murder but found not guilty by reason of insanity and detained in hospital — Claimant bringing claim in negligence in respect of his care in days preceding killings — Claimant seeking to recover for damage suffered by him as consequence of killings — Whether claim barred on grounds of illegality — Trial of Lunatics Act 1883 (46 & 47 Vict c 38), s 2 — Criminal Procedure (Insanity) Act 1964 (c 84), s 5

[2022] EWHC 1213 (QB); [2023] QB 229; [2022] 3 WLR 677; [2023] 2 All ER 254; [2022] WLR(D) 227, QBD

PUBLIC POLICY — Illegality — Civil claim — Claimant tried for murder but found not guilty by reason of insanity — Claimant bringing claim in negligence in respect of his care prior to killings — Claimant seeking to recover for damage suffered by him as consequence of killings — Whether claim barred on grounds of illegality — Trial of Lunatics Act 1883 (46 & 47 Vict c 38), s 2(1) — Criminal Procedure (Insanity) Act 1964 (c 84), s 5

[2024] EWCA Civ 138; [2024] KB 745; [2024] 2 WLR 1377; [2024] 3 All ER 833; [2024] WLR(D) 78, CA

PUBLIC POLICY — Illegality — Civil claim — Claimant tried for murder but found not guilty by reason of insanity — Claimant alleging killing result of defendants’ negligent failure to provide proper mental health care — Claimant seeking to recover for damage suffered by him as consequence of killings — Whether claim barred on grounds of illegality — Trial of Lunatics Act 1883 (46 & 47 Vict c 38), s 2(1) — Criminal Procedure (Insanity) Act 1964 (c 84), s 5

[2026] UKSC 2; [2026] WLR(D) 46, SC(E)

AI Summary & Issues

Content generated by AI, as supplied by Jurisage. Learn more about AI Case Summaries.

In Lewis-Ranwell v G4S Health Services (UK) Ltd and others, the Supreme Court ruled that the claimant's civil negligence claims were barred by the illegality defence, following his acquittal of murder by reason of insanity. The Court determined that the claimant's unlawful actions raised significant public policy issues concerning the integrity of the legal system. As a result, the appeal was allowed, upholding the lower courts' decisions to strike out the claims.

Issues

Did the court consider whether the claimant's civil claim in negligence was barred by the illegality defence due to his unlawful actions resulting in the killings of three men?
Was the determination of the claimant's mental state at the time of the killings relevant to whether the illegality defence applied to his claims for damages against the defendants?
Did the court assess whether allowing the claimant to recover damages would undermine the integrity of the legal system by permitting a person found not guilty by reason of insanity to benefit from his own unlawful conduct?

Appellate History

Lewis-Ranwell v G4S Health Services (UK) Ltd [2022] EWHC 1213 (QB); [2023] QB 229; [2022] 3 WLR 677; [2023] 2 All ER 254; [2022] WLR(D) 227, QBD

Decision of Garnham J affirmed

Lewis-Ranwell v G4S Health Services (UK) Ltd [2024] EWCA Civ 138; [2024] KB 745; [2024] 2 WLR 1377; [2024] 3 All ER 833; [2024] WLR(D) 78, CA

Decision of the Court of Appeal reversed

Lewis-Ranwell v G4S Health Services (UK) Ltd [2026] UKSC 2; [2026] WLR(D) 46, SC(E)

Commentary

Cambridge Law Journal
Illegality and insanity in tort law Case comment

Subscribe or Register to access the full case information page. Registered users can access three Law Reports, three case information pages and perform three Case Genie searches per month. If you already have an ICLR account please log in. For other queries or to request a free trial please contact ICLR.

MoJ users should log in here.