It seems "Qualified Immunity" is a specific doctrine from the SCOTUS and so not applicable, per that name at least, in Canada, the UK, nor anywhere else. See
Wiki for a decent starting point.
However, I find several cites indicating that English police do enjoy various forms of immunity including for
failure to warn/protect (known as
"Hill Immunity" it seems. This
case discusses issues of sovereign immunity of nations including Russia and England.
Frankly, I cannot determine whether or to what extent Canadian or English police officers might enjoy anything akin to Qualified Immunity in the USA. And so I can arrive at no informed opinion about what effect lack of QA might have on police conduct there or here. And having never lived there, I have no personal insights.
What I find curious and troubling however, is the extent to which some members are quick to take a single (potential) difference between US and UK law and credit it with vast differences in outcome. How is this materially different than what the gun grabbers do when they point to the difference in US and UK gun laws and proclaim/imply that single difference is responsible for the vast difference in murder rates between the US and UK?
Despite being divided by a common language, there are significant cultural differences between the US and the UK.
As discussed in some detail
at this site total violent crime in England and Wales may (or may not) be higher than in the US even though their homicide rate is lower than the US. I note that the racial/ethnic demographics of England are notable different than our own (91% white, 5% Asian, 2% black (and a few % others) with 92% of the population speaking English in England VS 63% "non latino" White, 5% Asian, 12% black, 16% Hispanic (and a few % others) with 76% speaking English and 11% speaking Spanish in the USA). England is far more homogenous of a society than is the USA.
Given the vast difference in overall homicide rate between the UK and US, it would be shocking if there were not similar difference in police officer killing of suspects or police officers killed in the line of duty as well.
It is easy to allow confirmation bias or something similar to effect us. I think there is some value to discussing the effects of QA. I think any attempts to suggest that (possible) differences in police immunity from nation to nation are themselves materially responsible for differences in police conduct is very difficult to support. Imagine the detailed statistical analysis that would be required to even begin to isolate this one aspect of law from all other influences of behavior, both legal and cultural.
There is no doubt that we have more officer-involved killings than in some other nations. There is also no doubt that we have more officers injured or killed in the line of duty than in some other nations. Did one lead to the other? And if so, which came first?
I think very hard to say.
Charles