Hill v Chief Constable of W Yorks Police [1998]

Estate of student murdered by Peter Sutcliffe brought
action against police for negligently failing to catch S and prevent murder.
House of Lords held there was nothing to take case out
of general rule denying duty of care in respect of wilful wrongdoing by others.
Police did not have S in their custody, and there was
no special relationship between police and plaintiff.
Also, imposing liability in such cases might encourage
police to carry out investigations with detrimentally defensive frame of mind.