October 2, 2025
Prison Officers Association v Iqbal (Rev 1) [2009] EWCA Civ 1312
A prisoner was confined to his cell during an unlawful strike by prison officers and sued their union for false imprisonment. The Court of Appeal held that an omission (the officers' failure to work) does not constitute false imprisonment, which requires a positive act of detention. Facts The claimant, Mr Iqbal, was a prisoner at HMP Wealstun. On 29 August 2007, the Prison Officers Association (POA), the defendant union, called its members out on an unlawful national strike in protest against the government’s decision to stage the prison service pay award. As a result of the prison officers’ absence, the
