This is a concerning scenario – my original correspondent provided more detail but to keep the question general I have edited the original question.
My SES Unit was asked by Police to help search for a mentally disturbed person who was known to be armed with a knife. The person was believed to be a threat to themselves not to others. Even so the police involved in the search were wearing their normal appointments (gun, baton, capsicum spray, Tazers). SES members were however tasked to the search and there insufficient police numbers to ‘buddy’ each SES member with a police officer.
On member raised a concern as to safety and was advised to “call on the radio” but there were not enough radios to go around and one could have been subject to a quick and violent surprise attack with no chance to call for help; and what could another member do who might have been close by?
I know I could have just “unvolunteered” and went home but that would not help my fellow members. I know the normal rules for self-defence apply but we had nothing to protect ourselves should the person have used a knife against us.
- Could we reasonably “arm” ourselves knowing the level of threat they are being sent into? Could one, considering its rough bushland carry a non SES issue, knife or machete? Or pick up a big stick?
- If all SES members refuse to help, what could the Police do?
- Does the SES response cover this situation?
- Who will be responsible for any injury to a SES member. Police or SES?
- Who will support any SES member, who injures such a person in this type of incident, against any legal threats civil or legislation?
- The Police would be operating under the NSW Mental Health Act, Where does the SES members stand under this Act in this situation?
The law of self-defence is set out in an earlier posts see
- Tasmania – Alcohol affected patient refuses treatment and is not guilty of assaulting police – Part 1 (October 5, 2015);
- Tasmania – Alcohol affected patient refuses treatment and is not guilty of assaulting police – Part 3 (October 6, 2015) and
- “No liability for police shooting” – number 2 and “Tasmania – Alcohol affected patient refuses treatment and is not guilty of assaulting police” – Part 5” (November 5, 2015).
‘Arming’ oneself is difficult. Of course carrying a stick is not in itself an offence. Carrying a knife might be illegal, carrying a machete would be. An offensive implement is ‘anything intended, by the person having custody of the thing, to be used to injure or menace a person or damage property’ (Summary Offences Act 1988 (NSW) s 1B(3)). It is an offense to have an offensive implement in a public place (s 1B(1)).
If you are carrying a stick or a knife or a machete for the purpose of ‘injuring’ or ‘menacing’ a person that is an offence unless you have a ‘reasonable excuse’. One might argue that looking for a missing mentally disturbed person gives rise to a reasonable excuse. In Taikato v R (1996) 186 CLR 45 Mrs Taikato argued that carrying a ‘pressurised canister of formaldehyde’ was lawful. She told police ‘she had had the canister for a few years and that, although she had never used it, she carried it so that she could defend herself if someone attacked her’. The High Court of Australia rejected her argument. They said that although using a weapon may be lawful in self defence. Chief Justice Brennan along with Justices Toohey, Mchugh and Gummow said:
The law authorises a person to assault another person in self-defence only when certain conditions are fulfilled. No legal right of self-defence arises until there is a reasonable apprehension of attack by the person who is assaulted… Because the existence of a right of self-defence cannot be determined until after the fact of a particular attack or threatened attack, it makes no sense, absent an actual or threatened attack, to talk of possession for self-defence as a “lawful purpose”. Self-defence in the colloquial sense is not a “lawful purpose” … Action in self-defence can only be taken for a “lawful purpose” when there is a lawful right entitling the person in danger of attack to take certain limited steps to use force against another person. It is only after the circumstances of the attack and the defendant’s response are evaluated that a court can determine whether the person was exercising the right of self-defence. Only then can it be determined whether a particular weapon was used for a “lawful purpose”. Accordingly, possession of a dangerous article for the purpose of “self-defence” is not possession for a “lawful purpose” …
Whether it’s a ‘reasonable excuse’ requires consideration of:
(a) the immediacy of the perceived threat to the person charged; and
(b) the circumstances, such as the time and location, in which the thing was possessed; and
(c) the type of thing possessed; and
(d) the age, characteristics and experiences of the person charged.”
For the SES volunteers in this question the ‘immediacy’ of the potential threat is much closer than for Mrs Taikato, but even so the question of whether or not ‘arming’ oneself was reasonable can only be determined after the fact taking into account all the factors. It’s hard to imagine a court would accept the SES arming themselves with a knife was ever a reasonable response to the risk as other responses are available. In short I would suggest it would not be ‘reasonable’ for the SES to arm themselves with a stick or a knife. If members are that concerned, they should simply refuse to take part in the search.
If the SES members refused to help, the police would have to find another solution, perhaps call in more police. No doubt they could complain to SES higher authorities but the better response would be to refer the matter up the chain of command of both organisations.
Does the SES response cover the situation? I’m not sure what is meant by that but one of the functions for the SES is ‘to assist, at their request, members of the NSW Police Force … in dealing with any incident or emergency (State Emergency Service Act 1989 (NSW) s 8(1)(g)). Taking part in this search would be a legitimate SES function. It follows that if a member of the SES were injured they would be entitled to compensation under the Workers Compensation (Bush Fire, Emergency and Rescue Services) Act 1987 (NSW).
Whether anyone would be found to be negligent or liable under the Work Health and Safety Act 2011 (NSW) would depend on all the circumstances and what happened. Remember that under the WHS Act the PCBU has to consider what is ‘reasonably practicable’ which includes
(a) the likelihood of the hazard or the risk concerned occurring, and
(b) the degree of harm that might result from the hazard or the risk, and
(c) what the person concerned knows, or ought reasonably to know, about:
(i) the hazard or the risk, and
(ii) ways of eliminating or minimising the risk, and
(d) the availability and suitability of ways to eliminate or minimise the risk, and
(e) after assessing the extent of the risk and the available ways of eliminating or minimising the risk, the cost associated with available ways of eliminating or minimising the risk, including whether the cost is grossly disproportionate to the risk.
Importantly there would be a risk in not searching for the person. The delay that may be occasioned in bringing more police to the scene may make that risk bigger. If the belief that the person is only a threat to themselves is based on the best available intelligence then it may be that even though it would be better to use police that is not ‘reasonably practicable’. In all the circumstances it may not be a breach of the WHS Act to use SES Volunteers but, one has to remember, that assessment really is a case by case judgement.
Assume the SES member did ‘arm’ him or herself and used that weapon when they found the person. In terms of civil litigation, members are not liable for acts ‘done in good faith’. Whilst that could be debatable one has to remember that the aim of civil litigation is to ensure a person who is entitled to compensation receives it. Actually arming oneself particularly with a machete may make the good faith argument hard to sustain but given the members were tasked with the search and depending on the specific instructions given, I suspect a court would want to find the SES (and so the NSW government) liable (should there be any liability) rather than a member.
Criminal liability is personal. That means if the member were charged with an offence under the Summary Offences Act or assault or worse where force is used in circumstances that do not amount to lawful self-defence then it is the individual who is liable. Even if the government agreed to pay the fine, the SES or the police don’t get the criminal record or go to gaol on the member’s behalf.
Members of the SES don’t have any authority under the Mental Health Act 2007 (NSW). Police may apprehend a person who is mentally ill and posing a threat to themselves or others. They may do that on their own initiative (s 22) or at the request of a treating medical practitioner (ss 19 and 49) or paramedic (s 21). The SES could assist the police in the search but have no specific power to detain the person if they find them. The police can of course ask for assistance so if a police officer were attempting to detain the person the SES could help because it is actually the police officer that is exercising the authority. Police may use ‘reasonable force’ in the execution of their duties (Law Enforcement (Powers and Responsibilities) Act 2002 (NSW) s 230) and just as that may include the use of a dog, so too calling upon the SES to ‘lend a hand’ to restrain someone may be a ‘reasonable’ use of force. If the SES found the person, and he or she was not acting violently or threatening suicide, the best action would be to try and keep everyone calm and wait for the arrival of police or, ideally, a mental health professional. If the person was trying to kill him or herself it is lawful to use reasonable force to prevent a suicide (Crimes Act 1900 (NSW) s 574B).
Important disclaimer
Clearly I am not making comments that could be applied to the specific search. I do not have all the facts or know the circumstances so this has to be read as a general statement of some relevant legal principles. If the members are concerned about the risk they were exposed to this should be raised through an appropriate chain of command rather than debated here. As noted this has to be read as an exploration of general principles only.
I would tend to agree with you Michael that this was a concerning situation from a common sense scenario as much as a legal scenario.
I understand and accept the ambiguity with which people may view mental health, who do not deal with it regularly, but from a medical perspective, the range of emotion, physical ability and motivators are very different from the perspective of each range of illness as well as each individual suffering from it.
The SES individuals posing the question understandably fail to understand that it is not common for mental health sufferers to be an unknown quantity. The media perpetuates the notion of mental health sufferers to be on a short fuse and ready to do something unexpected at a moment’s notice but the fact is that this is rarely the case.
Just as a thorough medical history will provide a wealth of information about each individual’s condition in typical medical ailments such as chest pain and or shortness of breath, what is common to mental health cases that is not to other medical ailments is each mental health presentation is often meticulously documented in some type of health database that gives even more of a thorough picture about what an individual suffers, how they suffer it and how they respond. Whilst there is always room for the unknown, chances of someone on the mental health service radar who does something unexpected is rare.
Further more, it is quite common for mental health sufferers to wish harm upon themselves, but would quite unlikely ever be in a position to wish harm on another person, even if that is their stated intention (In cases such as borderline personality) etc.
The police jurisdiction in question must have felt that they had enough information on the individual to make an informed decision about the suitability of bringing in non-armed emergency workers for the search. Again, whilst I understand that this may be difficult for people who do not work with mental health sufferers to comprehend, I challenge with this notion; we who work regularly with mental health sufferers in the health system are not armed. People present with a range of issues regularly, further, mental health nurses are expected to engage those with psychosis in the community who are not armed. Yes, where risk to the worker is possible, they will go in a group and will employ police should there be imminent risk. It sounds like this was being addressed in the circumstance in question.
Only where a person is psychotic and likely to attack staff is when a police first approach is taken, but this is quite a rarity.
In South Australia at least, an emergency worker is able to equip themselves with a knife or cutting tool where it is likely to be used in the course of their duties but that aside, I am concerned that one may feel the appropriateness of using cutting tools as a form of anticipated self defense. There are a multitude of reasons why police don’t carry them as a part of their standard response. I can not think of a personal, logical good that carrying a cutting tool in a professional capacity toward any individual could possibly achieve.
I hate to end with this but I feel that if an individual feels the need to wield a bladed arm in the search for a mentally unwell person and doesn’t understand why that sounds inappropriate, then they probably aren’t the best people to have on the search team for a mentally unwell person in the first place.
This scenario is 100% against VICSES SOP’s issued by State. Under no circumstances are VICSES members authorised to assist with searches of anyone who is armed or may pose a threat in such a way.
This stuff get’s my blood boiling! There are SOP’s, policies and procedures in place for a reason- to protect members from harm. Where’s the Duty of Care to the members?