On February 12, 2020, the Supreme Court of the United Kingdom (UK) issued its judgment in R (Jalloh) v. Secretary of State for the Home Department, holding unanimously that domestic common law on false imprisonment should not be aligned with the concept of deprivation of liberty under the European Convention on Human Rights (ECHR). According to a press release from the Court, the respondent had been released from immigration detention on bond, at which point a number of restrictions on his movement were imposed upon him, including requirements to regularly report to an immigration officer, live at a designated address, submit to e-tagging, and abide by an evening curfew. More than two years later, the Court of Appeal held in R (Gedi) v. Secretary of State for the Home Department that the Secretary of State did not possess the legal power to impose certain of the restrictions, which led to the respondent's curfew being lifted and to him filing for damages for false imprisonment. The High Court awarded him £4,000 and the Court of Appeal affirmed. The Secretary of State appealed to the Supreme Court arguing that the curfew should not be classified as imprisonment under the common law, and that, if it was, the common law concept should be adapted to be in line with the concept of deprivation of liberty under article 5 ECHR. In holding that the curfew did amount to false imprisonment, the Supreme Court further held that to align the domestic law on false imprisonment with the ECHR would be a "retrograde step" that would "restrict the classic understanding of imprisonment at common law to the very different and much more nuanced concept of deprivation of liberty under the ECHR." Whereas "[t]he Strasbourg court has adopted [its] approach because of the need to draw a distinction between the deprivation and the restriction of physical liberty . . . [t]here is no need for the common law to draw such a distinction." The Court therefore dismissed the Secretary of State's appeal.