This point may be demonstrated also by cases in which known suicide risks
have injured or killed themselves following admission to hospital. InThornev.
Northern Group Hospital Management Committee/1964) the patient's husband had
informed the nursing staff of his wife's threats of suicide, and the patient, who had
been undergoing treatment on a medical ward of a general hospital, was due to be
transferred from the ward to an outside neurosis unit for further assessment. She
was left unsupervised when both the nurse and the sister left the ward together.
The patient left the ward, returned home and committed suicide. The husband
failed in his action against the Hospital Management Committee. In the view of Mr
Justice Edmund Davies:
`The duty owed by hospital authorities and staff to a patient is that of reasonable
care and skill in the given circumstances. Whether a breach of that duty has
been established depends on the proven facts including what was known or
should have been known about a particular patient and the fact that the
defendants impliedly undertook to exhibit professional skill and administrative
care of reasonable competence and adequacy towards their patient. They must
take reasonable care to avoid acts or omissions which they can reasonably
foresee would be likely to harm the patient entrusted to their charge; but they
need not guard against merely possible /as distinct from reasonably probable)
harm. On the other hand the degree of care which will be regarded as reasonable
is proportionate both to the degree of risk involved and the magnitude of the
mischief which may be occasioned to the particular patient in the absence of due
care.'This case may be contrasted with that ofSelfev.Ilford and District Hospital Man-
agement Committee/1970) in which the plaintiff, whose attempt at suicide by a
drug overdose had failed, was admitted to a ward of 27 patients. The ground floor
ward contained four known suicide risks, grouped at one end of the room. Selfe, a
quiet and withdrawn man of 17, was left unattended on the ward when two of the
three nurses on duty left the ward without informing the third. While that nurse
was attending a patient elsewhere in the ward, Selfe climbed out of a window and
made his way up to a roof from which he jumped. His attempt at suicide again
failed, but he sued for his resultant injuries on the basis of negligent nursing
supervision. Evidence indicated that, even with all of the nurses on the ward, an
additional nurse was probably required. Mr Justice Hinchcliff found for the
plaintiff, stressing that the high degree of risk on the ward required a commen-
surate increase in the care provided.
There are a number of cases which show, however, that where the staffing is
adequate to meet the standard of care imposed upon the hospital or unit, a nurse
will not be liable for every untoward incident on a ward. Examples of this principle
include:Gravestockv.Lewisham HMC/1955) /injury following fall of nine year old
running in ward while nurse bringing food through to the ward);Coxv.Carshalton
HMC/1955) /inhaler slipped and scalded disabled minor as nurse away for matter
of seconds); andSizev.Shenley HMC/1970) unreported /nurse failed to reach
mentally unstable patient before he attacked the plaintiff).
Responsibility,LiabilityandScarceResources 137