October 5, 2025
Van Colle v CC of Hertfordshire Police [2008] UKHL 50
Giles Van Colle was murdered by a suspect he was due to testify against. The police knew of prior intimidation. His family sued the police. The House of Lords held there was no common law negligence liability but considered the police's positive obligations under Article 2 of the ECHR, clarifying the 'real and immediate risk' test. Facts Giles Van Colle was a key prosecution witness in a theft trial against his former employee, Daniel Brougham. In the months preceding the trial, Brougham engaged in a campaign of intimidation against Van Colle, including threatening phone calls and setting his car on
