September 16, 2025
In re L [1998] UKHL 24
Mr L, a profoundly mentally retarded autistic man, was informally admitted to a psychiatric hospital after a self-harming incident. The House of Lords held that his informal admission under section 131(1) of the Mental Health Act 1983 was lawful, and that treatment of compliant incapacitated patients could be justified under the common law doctrine of necessity. Facts Mr L was a 48-year-old man with autism and profound mental retardation who had been a long-term resident at Bournewood Hospital. In 1994, he was discharged on a trial basis to live with paid carers, Mr and Mrs E. On 22 July 1997,
