Mrs Reynolds was arrested by police during a raid on her home, despite having no reasonable grounds for suspicion of involvement in an arrestable offence. She was detained for a day at Limehouse Police Station. The Court of Appeal upheld the jury's award of £12,000 damages for false imprisonment.
Facts
Police were conducting widespread enquiries into suspected insurance fraud involving arson of properties in East Anglia. Mr Reynolds, the Plaintiff’s common-law husband, was suspected of involvement in fires at properties including The Maltings, which had been purchased cheaply but insured for over half a million pounds. On 23rd February 1976, police raided Bardwell Hall where Mrs Reynolds lived with Mr Reynolds. She was arrested, taken to Limehouse Police Station (a journey of two and a half hours), detained throughout the day, interviewed, and eventually released at approximately 8pm, arriving home around 11pm.
Grounds for Arrest
The only grounds police had for suspecting Mrs Reynolds were: (1) she had visited The Maltings; (2) she was secretary to Mr Reynolds; and (3) she was living with him. Police also drew parallels with another suspect, Mr Allan, whose mistress had become involved in purchasing properties.
Issues
The appeal raised three main grounds:
- Whether the trial judge’s ruling that there were no reasonable grounds for suspecting Mrs Reynolds of an arrestable offence was wrong;
- Whether the judge’s directions to the jury on damages were defective;
- Whether the £12,000 damages award was excessive.
Judgment
The Court of Appeal unanimously dismissed the appeal.
On Reasonable Grounds for Arrest
Lord Justice Waller held:
“In my judgment, the learned Judge was quite right in his tests; there really was nothing on which the Police could have a reasonable suspicion that Mrs Reynolds was involved in the commission of an arrestable offence.”
Lord Justice O’Connor added:
“The only connection they suggested Mrs Reynolds had with that matter was that she was his common-law wife… Mr Gibson, who was in charge of this part of the case, simply said for this reason ‘she had to be in on it’ – but that was not a good ground for arresting her.”
On the Standard for Arrest
Lord Justice O’Connor explained the proper test:
“It is important to remember that the Police are not bound to arm themselves with prima facie evidence of guilt before they make an arrest for an arrestable offence. It is quite sufficient that they have information which, as reasonable people, leads them to believe that the suspect may be guilty of the offence.”
On Damages
The Court found the summing-up on damages was proper. While the direction on exemplary damages was not entirely correct, the jury confirmed they had not included any exemplary element in their award. Lord Justice Waller approved the trial judge’s conclusion:
“Measure it rather than inflame it or set fire to it. Do not belittle or extinguish it. Approach your task rather coldly but accurately.”
On Quantum
While acknowledging the award was high, the Court held it could not be said that no reasonable jury could have arrived at that figure.
Implications
This case clarifies the standard for reasonable suspicion required for lawful arrest. Mere association with a suspect, even as a common-law spouse, is insufficient to establish reasonable grounds for suspicion of involvement in criminal activity. The case also provides guidance on damages in false imprisonment claims, particularly regarding the distinction between compensatory and exemplary damages, and confirms that appellate courts will not interfere with jury awards unless they are so high that no reasonable jury could have made them.
Verdict: Appeal dismissed. The trial judge’s ruling that there were no reasonable grounds for suspecting Mrs Reynolds of an arrestable offence was correct, the directions on damages were adequate, and the £12,000 damages award was upheld as not being so excessive that no reasonable jury could have arrived at it.
Source: Reynolds v Metropolitan Police Commissioner [1982] EWCA Civ 7
Cite this work:
To cite this resource, please use the following reference:
National Case Law Archive, 'Reynolds v Metropolitan Police Commissioner [1982] EWCA Civ 7' (LawCases.net, January 2026) <https://www.lawcases.net/cases/reynolds-v-metropolitan-police-commissioner-1982-ewca-civ-7/> accessed 16 April 2026
