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23 January 2026 / Neil Parpworth
Issue: 8146 / Categories: Features , Liability , Tort , Public , Contempt , Rule of law
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Chief constables: in the dock

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Are chief constables vicariously liable for the actions of their officers & staff? Neil Parpworth examines the case law
  • In Buzzard-Quashie v Chief Constable of Northamptonshire Police, the issue arose as to whether or not a chief constable can be vicariously liable for contempt.
  • In light of the Court of Appeal’s decision, such liability covers a situation where a police force has failed to comply with a court order.
  • The court imposed a fine on the chief constable to be provided out of the force’s existing budget.

Section 2(1) of the Police Reform and Social Responsibility Act 2011 provides that each police force is to have a chief constable, and by virtue of s 2(3), a police force and its associated civilian staff are under their direction and control. Until the Police Act 1964, torts committed by police officers were not actionable as against chief constables. Rather, a claimant was required to seek redress against the individual officer concerned.

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