Three face-down restraints and a towel across the door

Held face down three times and penned in with a towel. Two courts took different views of the towel.

School · 2020s · Method: Prone restraint

What happened

He was nine when he started at a residential special school in Oxfordshire in June 2008, and left fifteen months later, in September 2009.

Staff restrained him 117 times in that period. Three were face down: held on the ground with weight on his back, and one on a bed. On other occasions a towel was wrapped around the inside handle of his bedroom door and the door pulled to.

His father says the school questioned his autism diagnosis, per the Guardian’s report of 20 December 2024. He sued in negligence, assault and false imprisonment.

The outcome

The trial ran nine days over a year. On 10 June 2024 Ms Justice Obi found the three face-down restraints were battery and the towel incidents false imprisonment, fourteen times. Negligence failed: the restraints were, in the main, “a last resort in the context of a well-managed school environment”. The award of 8 November 2024 came to £18,900, including £7,000 in aggravated damages.

On 1 April 2026 the Court of Appeal took most of that away ([2026] EWCA Civ 415). It dismissed the school’s appeal on the face-down holds, upholding the judge’s finding of unreasonableness. It allowed the appeal on the towel, holding the confinement each time no more than reasonable to prevent injury and let him calm with staff still speaking to him. The aggravated damages went in full, leaving £6,000.

What went wrong

A technique nobody owned. The school’s expert said the face-down holds “were not taught techniques, so they were not techniques”. They were unplanned interventions, written up like any other incident.

Deployment. Two holds happened when a small, slight member of staff was alone with him, his behaviour being entirely predictable. The Court of Appeal held the school could not reasonably have put her there, and that the next option after a failed wrap is supine.

The notes. One witness suggested that a note recording him held on the ground with weight on his back might have been describing him on his side. The Court of Appeal also found the judge had read the 15 May note as nearly five hours of confinement when part of it came before he went upstairs.

What it teaches

The prone hold survived two courts; the policy argument did not. A school can win on negligence and overall quality and still lose on three afternoons, because compliance with guidance is not the legal test; reasonableness in that incident is.

A door held shut is not automatically false imprisonment either. Here it was short and reasonable, staff still talking to him. The difference between that and a child behind a barrier with nobody there is the whole case.

And the record is the evidence: a duration the note cannot support will not survive an appeal.

Questions for the room

Evidence and limits

Confidence: confirmed. The Guardian’s report of 20 December 2024 and the Court of Appeal judgment, from ICLR’s text of 1 April 2026, were read on 7 November 2026. BAILII returns a bot challenge on both High Court judgments, so the 2024 findings rest on the record and the press.

A court order anonymises the boy and his father; naming the school alongside these facts would identify him. No member of staff is named: none was convicted and no regulator determination names them.

Our positive handling training for schools covers prone restraint and how to record it defensibly.

Sources

Reviewed 7 November 2026.

All school cases  ·  Education Casebook

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