An Informer v A Chief Constable [2012] EWCA Civ 197, [2012] All ER (D) 31 (Mar)
The imposition of a duty of care for the safety and welfare of the covert human intelligence source (CHIS) would be consistent with the purpose of the relationship being one of confidentiality. Given the physical risks to which a CHIS was exposed, it was just and reasonable that the police should owe a duty of care for the safety and welfare of a CHIS. However, it would not be fair, just and reasonable for the police to owe a duty of care that extended to general financial wellbeing.
Further, given the purpose of the use by the police of informers, the prospective harm against which the police might be held to owe a duty of care towards a CHIS had to be limited to risks which were due to his conduct in assisting the police by giving them information about others. If the information raised, or led to a train of investigation which raised, suspicions of criminality on his own part, the police could not owe him a duty which would conflict
