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IN THE COURT OF APPEAL BETWEEN: LEDWORTH POLICE FORCE ‘Appellant -AND- LEYMAN AND ERY Respondents SKELETON ARGUMENT ON BEHALF OF THE APPELLANT GROUND (1) Author Hill v Chief Constable of Yorkshire (1988) 2 WLR 1049 Smithy Chief Constable of Sussex Police {2008} 3 W.LR. 593 Ovnan y UK (1998) 29 EHRR 245 Ground _of Appeal ‘The Appellant did not owe the chimants ake Leyman and Philp Fry) a duty of care, in which ‘they were allegedly in breach of by not providing adequate protection 10 Pat Leyman (“the victim”). ‘Submis sions 1. Following the House of Lords, in Hill v West Yorkshire Police, the police do not owe a duty of care to protect members of the public at no special or particular risk of harm therefore the Appellant is not lab for dammges arising fiom the victim's murder. A common law negligence chim shoull not be allowed against the Appellant in the interest of the wider community. The majority in Smithy Chief Constable of Sessex Police should. be followed, and Lord Bingham’s “lability principle” should dsr garded. 3. The Appelant did not fal to provide “adequate protection” to the victim according the guidance provided by the Commission in. Osman v UK. Conclusion No-duty shoukl imposed on the core functions of the police, therefore the decision to award damages should be reversed. Mustafa. Khan, 2 February 2015

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