An unusual situation arose in Makanjuola v Commissioner of Police for the Metropolis (1992), The Times, 8 August 1989 in which a Nigerian woman unsuccessfully claimed against the Police Commissioner for intimidation and sexual assault. She had consented to sex in return for a police officer refraining from reporting her alien status to the immigration authorities. Although s 48 Police Act 1964 stated that the Commissioner of Police would be vicariously liable for the actions of his police officers, this would only apply if such acts were in the course of the police officer’s employment. The police officer’s actions were not in the course of his employment.