AI-generated statements condemned by the Court of Appeal

R v Jerome Gibson [2026] EWCA Crim 1302, 22 September 2026, judgment here

The Court of Appeal has issued a stark warning about the use of artificial intelligence in criminal proceedings after discovering that a police officer used Microsoft Copilot to generate a victim personal statement (‘VPS’) designed to maximise emotional impact and so influence the sentencing of an offender.

Whilst this is not a judgment arising from an inquest, given the unrelenting march of AI generated content already appearing in submissions in Coroner’s Courts this case nevertheless provides a stark early warning about the misuse of artificial intelligence (‘AI’) in any judicial forum.

Murder, forfeiture and the right to arrange the funeral

Bains v Arsalan & Anor (Funeral Arrangements) [2026] EWHC 1597 (Fam), Peel J 23 June 2026. Judgment here

What happens when the person ordinarily entitled to arrange a child’s funeral is the person convicted of murdering her?

That was the issue Peel J had to consider in this case looking at the relationship between the forfeiture rule, the statutory power to pass over a prospective administrator and the court’s inherent jurisdiction.

The facts

Harleen, who had been born into the Sikh faith, was two months old when she died from catastrophic injuries. Her (unmarried) parents had been the only persons present when she was injured. Her mother, who had sole parental responsibility, gave what she later admitted was a false count that Harleen had wriggled out of her arms and fallen.   After Harleen’s father took his own life her mother changed her account to allege that he had assaulted both her and Harleen, knocked her unconscious and killed Harleen.

Six years after Harleen’s death her mother was convicted of her murder and sentenced to life imprisonment with a minimum term of 19 years. Harleen’s body had meanwhile remained unburied under the responsibility of the Coroner’s Office…

Privilege and compelled disclosure: The limits of a coroner’s power to obtain a family’s expert report

Re Margaret Drake’s Application for Judicial Review [2026] NICA 17 (judgment here)

The Northern Ireland Court of Appeal has revisited a tricky question in inquisitorial proceedings: when the bereaved have obtained their own expert report for an inquest and decide against relying upon it, can the coroner compel its production?

As is often the case, the answer is fact-sensitive, but on the facts of this case the Court of Appeal overturned the decision of the judge below and quashed the Coroner’s refusal to revoke a notice requiring a family’s expert report to be provided to her.

Although this was a decision interpreting sections 17A and 17B of the Coroners Act (Northern Ireland) 1959, given the symmetry between the Northern Irish statutory scheme and coronial powers in England and Wales, it is still highly persuasive and so the principles applied require close analysis by inquest practitioners and coroners in England and Wales.

Coronial Law Short Course: University of Greater Manchester 2026–27

Commencing Thursday 15th October 2026

The Centre for Contemporary Coronial Law at the University of Greater Manchester has announced that the highly successful Coronial Law ‘Short Course’ will be offered again, starting on Thursday, 15th October 2026.  All (seven) sessions are conducted live via Microsoft Teams from 18:00 to 20:30.

Designed for practitioners working in, with, or aspiring to join the coronial service, the course blends clear legal foundations with practical, court-facing learning to build confidence and understanding in relation to coronial investigations and inquests.  It is ideal for legal representatives, hospital coronial liaison staff, coroners’ officers, those seeking coronial roles, newly appointed coroners, and others involved in the investigation of deaths and the inquest process.

Course Schedule:

  • 15 October 2026
    Lecture 1 – Introduction and Outline
    Alan Wilson HM Senior Coroner, Blackpool and Fylde
  • 29 October 2026
    Lecture 2 – Jurisdiction and Investigations
    Professor Christopher Dorries OBE Retired HM Senior Coroner, South Yorkshire West
  • 12 November 2026
    Lecture 3 – Seminar / Case Studies
    Professor Christopher Dorries OBE Retired HM Senior Coroner, South Yorkshire West
  • 26 November 2026
    Lecture 4 – Inquests (Part I)
    Rachael Griffin HM Senior Coroner for Dorset
  • 10 December 2026
    Lecture 5 – Inquests (Part II)
    Rachael Griffin HM Senior Coroner for Dorset
  • 14 January 2027
    Lecture 6 – Article 2 Inquests
    Timothy Brennand HM Senior Coroner, Manchester West
  • 28 January 2027
    Mock Inquest
    Course Faculty

Course Details

  • All sessions will be conducted live via Microsoft Teams from 18:00 to 20:30.
  • The cost is £50 per individual session, or £300 for the complete course.
  • Participants may book the complete course (seven sessions) or select individual sessions according to their professional interests.
  • An employer invoice booking option is also available for organisations wishing to pay by invoice.

To Book Your Place click here:  Book the Coronial Law Short Course

LLM Coronial Law – October 2026 Intake

The Centre for Contemporary Coronial Law also has a small number of places remaining on its LLM in Coronial Law commencing in October 2026.

The LLM is designed for those wishing to develop a more advanced and specialist understanding of coronial law, practice and death investigation.

Further information about the LLM, including entry requirements and how to apply can be found here or by contacting the Centre using the same contact details below.

Contact Information

For further information about the Coronial Law Short Course or the LLM in Coronial Law please contact:

Dr Alicia Danielsson
Head, Centre for Contemporary Coronial Law
University of Greater Manchester

Email: CoronialLaw@greatermanchester.ac.uk

Cover-ups, Coroners and Custody

R v Foster [2026] EWCA Crim 1088, 7 August 2026 (judgment here)

This appeal case, considering the length of sentence for perverting the course of justice, should operate as a stern warning of how seriously criminal courts will view giving false accounts in anticipation of coronial investigations.

The Facts

Mrs Froggett, an elderly care home resident died from complications of a fractured femur after an unobserved fall from her wheelchair. The care home manager (a registered nurse), together with two care workers, created and maintained a false account that her wheelchair lap strap had been fastened when Mrs Froggett fell.

That false narrative was set out in documents produced in the knowledge that investigations by the CQC and coronial proceedings were likely to follow her death. It was also repeated in responses sent to the coroner, which went as far as suggesting that the deceased may have unfastened her lap belt herself and that the lap strap’s buckle had become defective or gone missing after the incident.

The deception came to light only because the participants were stupid enough to discuss their falsehoods in the presence of an honest staff member who properly reported the overheard discussions about the fabrication. Approximately six months later fresh accounts were produced admitting that the earlier statements had been false.  Indeed it seems that the lap strap had never even been capable of being fastened because the buckle was missing. Their false accounts had clearly included quite despicable victim blaming.