Clunis v Camden and Islington HA [1998] 3 All ER 180
Court of Appeal
Basic Facts: C, who had mental health issues, was detained in a hospital but later discharged without adequate psychiatric follow-up. C then killed a man, Z, in an unprovoked attack and was convicted of manslaughter due to diminished responsibility. C sought damages from D, alleging their negligent care led to his conviction.
Issue for the Court: Can C claim damages from D when C's own illegal act (manslaughter) resulted from D's alleged negligence?
Held : The case was struck out as the court ought not to allow itself to be made an instrument to enforce obligations alleged to arise out of the claimant's own illegality
Bedlam LJ:
The general maxim is that courts should not enforce illegal contracts or allow claims arising from illegal acts.
Even though Cās criminal responsibility was diminished, the court could not entertain his claim because his act arose from his own illegal wrongdoing.