Risk assessment, the HTT and bed availability: causation in a tragic mental-health claim
Ridge v Dorset Healthcare University NHS Foundation Trust [2026] EWHC 898 (KB)
In a judgment handed down on 17 April 2026, Edmund Burge KC (sitting as a Deputy Judge of the High Court) dismissed a claim arising from a catastrophic act of self-harm by a young man with a documented history of suicidal ideation and attempts. The judgment is a careful and, in places, painful illustration of how the law approaches psychiatric risk assessment, the role of the Home Treatment Team (“HTT”) and the evidential burden on a claimant who must establish, on the balance of probabilities, that earlier or different action would have averted the index event.
Facts
On 29 April 2021, the Claimant, Mr Benjamin Ridge, climbed an electricity pylon near his home in Weymouth and sustained a near-fatal electric shock, falling some 20 feet to the ground. His injuries included extensive burns, fractures to two vertebrae and an above-knee amputation of the right leg. In the months and weeks beforehand, he had been in active contact with the Defendant’s mental-health services. The diagnostic picture included Depressive Disorder, PTSD and Generalised Anxiety Disorder, with fluctuating mood, intrusive suicidal ideation and a striking pattern of alarming self-harm attemptson 21, 26 and 27 April). His personal diary contained an entry expressing a desire to die.
Two days before the index event, on 27 April 2021, the Claimant was assessed by Dr Trendafilov, a locum CMHT Consultant Psychiatrist. Dr Trendafilov recorded a “very low” mood and that the Claimant had “had enough”, but also noted some insight, fluctuation in affect, family engagement and the absence of any active plan. The risk of self-harm and suicide was assessed as “moderate”. Dr Trendafilov increased Mirtazapine from 30mg to 45mg, prescribed Zolpidem to assist sleep, and arranged a follow-up appointment for 30 April. He did not refer the Claimant to the HTT.
Issues
By trial, the Defendant had conceded that Dr Trendafilov should have referred the Claimant to the HTT. Three issues remained: (i) whether the “moderate” (rather than “severe”) risk assessment was itself negligent; (ii) whether, on a proper referral, the HTT would have recommended immediate inpatient admission; and (iii) whether, on the balance of probabilities, a suitable bed would in fact have been available before 29 April.
Decision
On breach, the Deputy Judge preferred the Defendant’s expert, Dr James Eldred, to the Claimant’s expert, Dr Trevor Turner, and held that the “moderate” categorisation fell within the range of reasonable psychiatric opinion. Despite the alarming history, there were genuine and identifiable protective features: the Claimant’s insight, his engagement with services, his capacity to resist impulses, his fluctuating affect and his demonstrable forward planning. The assessment was not Bolam-negligent and was logically defensible for Bolitho purposes.
On causation, the claim failed twice over. First, the HTT, properly directed, would not have recommended admission. The HTT’s orientation – consistent with the modern least-restrictive-option philosophy – favoured intensive community support over inpatient care for a patient with this presentation, and that approach was itself Bolitho-defensible. Second, even had admission been recommended, the evidence did not establish, on the balance of probabilities, that a suitable bed would have been available before the index event. Bed scarcity in adult mental-health services meant that the limited availability that did exist was reserved for patients categorised as “very high risk”, a category into which the Claimant, on the contemporaneous picture, did not fall. A single bed identified on 28 April was unlikely to have been allocated to him.
The claim was accordingly dismissed.
Comment
Ridge is a sobering decision, and one which will repay close reading by practitioners on both sides of clinical negligence litigation.
First, it is an illustration of a firm application of Bolam and Bolitho to psychiatric risk stratification. The judgment underlines that risk assessment is a clinical judgment exercised on the totality of the picture, not a tick-box exercise driven by the most alarming items in the history. The presence of multiple recent attempts (including pylon climbs in the days immediately before the assessment) did not, of itself, mandate a “severe” rating where there were identifiable and contemporaneous protective factors. Claimant practitioners should be slow to assume that a retrospectively obvious adverse outcome is sufficient to establish negligence in the prospective assessment.
Second, the decision is a useful reminder that the HTT is not a synonym for admission. The least-restrictive-option principle, embedded both in the Mental Health Act framework and in modern NHS guidance, means that even a proper HTT referral may legitimately yield a community-based intervention. Pleading a causation case that depends on inpatient admission therefore requires careful expert support not only as to whether the HTT should have been involved, but as to what the HTT, properly engaged, would in fact have done. Ridge is the latest in a line of cases (compare the Rabone line of authority) in which the gap between referral and admission has proved decisive.
Third, Ridge reinforces the increasingly important role of bed-availability evidence in mental health causation claims. Claimants must adduce contemporaneous evidence about the state of the local bed base, the prioritisation criteria then in operation, and the realistic prospect of a bed being released to the index patient. Generalised assertions that “a bed would have been found” are unlikely to carry the day. Defendants, conversely, should now expect routinely to disclose ward state reports and bed-management records as part of the causation enquiry.
Finally, the judgment is a quiet endorsement of the proposition that, in mental health claims, the breach and causation analysis must be conducted patient-by-patient and decision-by-decision. The natural human reaction to a history of repeated self-harm attempts is to assume that more should have been done; the law, properly applied, asks instead what would have been done by a competent clinician, and what difference, if any, it would have made. On the facts of Ridge, neither limb was made out, and the claim failed accordingly.
