In Vellino v Chief Constable of Greater Manchester [2002] 1 WLR 218 the police arrived at the claimant’s flat and arrested him on an outstanding warrant. The claimant managed to free himself from the police and jumped from a second floor window. The court held that no duty of care existed and, in any event, by breaking away from custody, the claimant was committing a crime and ex turpi may well apply.