October 2, 2025
R v Governor of Brockhill Prison, ex parte Evans [2000] UKHL 48
A prisoner was detained for 59 days beyond her lawful release date because the prison governor miscalculated her sentence based on a legal interpretation that was later overruled. The House of Lords held this was false imprisonment, a tort of strict liability. Facts The appellant, Michelle Evans, was serving consecutive prison sentences. The prison governor’s staff calculated her release date in accordance with the prevailing interpretation of the relevant sentencing provisions, as established in R v. Governor of Blundeston Prison, Ex parte Gaffney [1982] 1 W.L.R. 696. However, a subsequent High Court decision, R v. Secretary of State for the
