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Campbell v SS Kresge Co Ltd et al, [1976] 74 DLR (3d) 717 (NSSC)


Campbell leaves store. Another shopper tells officer that she might have stolen something. Officer goes outside after her and asks her to come inside to his office to avoid any embarrassment. Campbell reluctantly follows. She stops to asks officer what it is about. Seeing that his informant has disappeared, he lets Campbell leave.


Did the police officer's actions constitute false imprisonment?


Restricting a person’s lawful movement by threat of non-physical harm given from a position of authority (duress) constitutes false imprisonment.


The officer used the force of legal authority to take Campbell in a direction she did not want to go. He threatened embarrassment. She followed out of fear of the consequences if she was to refuse.

But no scene was created that would have brought her in disrepute.


Decision in favour of Campbell (awarded 500$).

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