The Chief Constable of the Greater Manchester Police v McNally: CA 25 Jan 2002

The claimant sought damages against the police for malicious prosecution and otherwise. He sought disclosure of whether a party referred to in the case as X, had at any time been a paid informer. The police appealed an order to disclose this. Counsel for the police had sought to rely upon assertions made as to X’s behaviour. The judge refused a public interest immunity certificate.
Held: The general rule is against disclosure of informant’s identities even in civil cases, but there are exceptions, including the need to avoid a miscarriage of justice. In this case there was such a risk, and the judge’s order stood. The judge need not restrict himself to the list of exceptions in the NSPCC case.


Lord Justice Auld, Lord Justice Robert Walker, And, Sir Christopher Slade


Times 06-Mar-2002, [2001] EWCA Civ 14, [2002] Crim LR 832




England and Wales


CitedMarks v Beyfus 1890
The plaintiff claimed damages for malicious prosecution. He called the Director of Public Prosecutions as a witness, who refused to identify the name of the person who had given him the information on which he had acted against the plaintiff.
CitedSavage v Hoddinot (Chief Constable of Hampshire) CA 6-Feb-1997
A police informer may abandon anonymity to sue police for promised fees. . .
CitedD v National Society for the Prevention of Cruelty to Children HL 2-Feb-1977
Immunity from disclosure of their identity should be given to those who gave information about neglect or ill treatment of children to a local authority or the NSPCC similar to that which the law allowed to police informers.
Lord Simon of . .
Lists of cited by and citing cases may be incomplete.

Human Rights, Police

Updated: 04 July 2022; Ref: scu.167466