The position is different, however, where the complaint is that the police have been negligent in their investigations to catch criminals. In Hill v Chief Constable of West Yorkshire [1989] AC 53, the mother of the last victim of Peter Sutcliffe, the ‘Yorkshire Ripper’, sued the police for negligently failing to apprehend Sutcliffe earlier. He had been questioned by police and released and had subsequently murdered again. The House of Lords refused to impose a duty of care as there was insufficient proximity between any woman, as a potential victim of a crime, and the police. Also, on policy grounds, the threat of liability in such cases would lead to the police adopting defensive practices and may result in both a waste of resources and inefficient use of police manpower. The approach taken in Hill was confirmed by the House of Lords in an appeal concerning the friend of the murdered Stephen Lawrence, who was with Lawrence at the time of the attack, and who suffered post-traumatic stress as a result of his treatment by the police (Duwayne Brooks v Commissioner of Police for the Metropolis [2005] UKHL 24 in Horsey and Rackley).