Negligence – Causation. The Queen's Bench Division held that in a claim for medical negligence in respect of the death of a prisoner by his former foster parent and their son, the claimants, that although the foster parent did have victim status under art 34 of the European Convention on Human Rights, the claimants had failed to establish violations of arts 2 and 3 of the European Convention on Human Rights and accordingly their claims were dismissed.