An end to the Plus of Galbraith in Inquests?

R (Police Officer B50) v HM Coroner for East Yorkshire and Kingston Upon Hull [2023] EWHC 81 (Admin) The Divisional Court (Stuart-Smith LJ and Fordham J) considered a challenge to a Coroner’s application of the Galbraith test as to what conclusions can safely be left to a jury in an…

Fresh Inquest into Death by Suicide Following Cessation of Benefits is Granted

Joy Dove v (1) HM Assistant Coroner for Teesside and Hartlepool and (2) Dr Shareen Rahman [2023] EWCA Civ 289 In Issue 10 of QMLR, I considered the judgment of the Divisional Court that refused the Applicant’s four grounds seeking an order to quash the Coroner’s determination. That article, and…

Fresh Inquests

Mays v HM Senior Coroner for Kingston Upon Hull & East Riding of Yorkshire [2021] EWHC 3604 (Admin) Earl v HM Senior Coroner for East Sussex [2021] EWHC 3468 (Admin) R (on the application of Ginn) v HM Senior Coroner for Inner London [2022] EWHC 28 (Admin) Three recent applications…

Withdrawal of Benefits, Article 2 and Inquests

Dove v HM Assistant Coroner for Teesside and Hartlepool [2021] EWHC 2511 (Admin) Facts Ms Whiting had spinal conditions since her early twenties, which gave her back pain, required surgery, and regular painkillers. She also had a history of mental health problems (depression, drug dependence, and emotionally unstable personality disorder)…

Application for Fresh Inquest Refused

Farrell v HMC for North East Hampshire [2021] EWHC 778 (Admin) Applying for a fresh inquest is not straightforward. First, the bereaved have to get permission from the Attorney General. Only once that authority has been granted will they be allowed to apply to the High Court to reopen the…

A Fresh Inquest – Necessary or Desirable?

HM Senior Coroner for Gwent, Re Inquest into the Death of Vaughn, Re [2020] EWHC 3670 (Admin) A fresh inquest was ordered by the High Court in circumstances where the Deputy Coroner had been unaware of the presence of a suicide note which later came to light. Facts In April…

Article 2 and Police Failings

R (Peter Skelton and anr) v Senior Coroner for West Sussex [2020] EWHC 2813 (Admin) Susan Nicholson and Caroline Devlin were killed by the same man during the course of abusive relationships. They died in 2011 and 2006, but the man was not convicted – of murder and manslaughter respectively…