false imprisonment

Q2771. What amounts to false imprisonment?

Where a person is intentionally confined without legal authority, such confinement amounts to false imprisonment. Also, imposition of unlawful restrain upon another by force, threat of force or show of authority is false imprisonment.

Q2772. What is the form that restrain must take to amount to false imprisonment?

The retrain must be total to amount to false imprisonment. Partial restrain is actionable perhaps as nuisance but not false imprisonment. Ajagu v. UBN Ltd. & Anor. (1986) Vol. I QLRN 184.

Q2773. State the elements of false imprisonment

The elements of false imprisonment are the following:

  • a. Intent to confine another person against their will.
  • b. Actual imprisonment resulting in the confinement of a person against their will.
  • c. Absence of a reasonable means of escape.

Some jurisdictions require the following in addition to the above:

  • a. Awareness of the confinement by the person confined.
  • b. Absence of legal authority on the part of the person acting to confine another.

Q2774. When will a defendant be liable for false imprisonment?

A defendant will only be liable for refusing to release a person when his obligation to do so arises. Herd v. Weardale Steel, Coal & Coke Co. Ltd. (1915) AC 67.

Q2775. What is the position of false imprisonment in relation to the power of the police to detain a person?

There is police privilege whereby a police officer has the right to detain someone if he has probable cause to believe a crime has been committed and that the person is so involved, or if the officer has reasonable suspicion that the person has been, is, or is about to be, engaged in criminal activity based on specific or particularized facts. The detention of such a person does not amount to false imprisonment.

Q2776. Is a person who merely gave information leading to the arrest of a person liable in an action for false imprisonment?

An action for false imprisonment cannot lie against a person who merely gave information or made a report of a person leading to the police on its own initiative, to arrest a suspect. However, the protection afforded a person in reporting a felony would be lost where the information is found to be false. Such person will be held liable for the consequences of the arrest and damages flowing therefrom. S.P.D.C (Nig.) Ltd. Chief Olanrewaju (2003) FWLR (Pt. 140) 1640.

Q2777. What must the plaintiff show in order to succeed in an action for false imprisonment?

For a plaintiff to succeed in an action for false imprisonment, he must show that the defendant was actually instrumental in setting the law in motion against him. The defendant usually, must have done more than merely passing information to the police. Borno State Government v. Alhaji Ashieik & Ors. (2007) All FWLR (Pt. 357) 1006.

Q2778. Upon what is the damages for false imprisonment based?

Damages for false imprisonment generally is worked on the loss of dignity that is considered as injury to feelings, that is, the dignity, mental suffering, disgrace and humiliation with any attendant loss of the station to be assessed at the discretion of the court. Ajagu v. UBN Ltd. & Anor. (1986) Vol. I QLRN 184.

Q2779. Does a defense against false imprisonment exist?

Justification in an action for false imprisonment could be found on defense to the person or property of the defendant, stopping a breach of the peace, or use of reasonable force in the prevention of a crime, or in effecting or assisting a lawful arrest of offenders or suspected offenders or persons unlawfully at large, acting in aid of the officers of the law, in protecting danger to the plaintiff or others, chastisement in administration of parental or other authority. Mtsor v. Adeke (2005) All FWLR (Pt. 287) 872.

Q2780. What are the remedies available to a plaintiff in an action for trespass to his person?

The remedies available to a plaintiff in action for trespass to his person include the following:

  • a. A declaratory judgment of the right of the plaintiff to enjoy the fundamental right to dignity of human person, right to freedom of movement or right to personal liberty.
  • b. Award of damages.
  • c. Apology.
  • d. Writ of habeas corpus.
  • e. Injunction.