Negligence – Causation. The claimant, who had a history of mental health issues, sustained his head injuries outside the Accident and Emergency Department whilst en route from a police station to hospital pursuant to being 'sectioned' under section 2 of the Mental Health Act 1983. He brought a clam against the defendant NHS trust. The Queen's Bench Division held that the trust was liable as the security guards had failed to take reasonable steps to ensure the safety of the claimant; and that failure caused him to suffer injury.