Fennell, Letts and Wilson, Mental Health Tribunals (Law Society 2013):
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Clunis v UK 45049/98 (1998) ECHR 116

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The failures in providing care prior to the claimant's offence did not breach Article 8 as there was no inevitable link between the failures and the offence; although he lost his negligence action against the local authority (partly on the basis of ex turpi causa) there had been no breach of Article 6 in the procedure.

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