R (Przybys) v Chief Constable of Greater Manchester Police [2026] EWHC 1159 (Admin) 15 May 2026 (judgment here)

This Administrative Court decision reviews the interrelationship between police investigations, regulatory processes and coronial decision-making.  Although the Senior Coroner for Manchester City was not a party to these proceedings, the court identified the coroner’s earlier assessment of this being a natural death that did not require an inquest, as a factor which Greater Manchester Police (‘GMP’) was entitled to take into account when deciding not to launch a criminal investigation into alleged gross negligence manslaughter.

Any coroners still smarting after being referred to as a ‘lower judicial officer’ in the Norfolk [1]case may now take some comfort from Coppel J’s recognition of the legitimacy of police decision-making being informed by the position of the ‘expert’ Coroner.

Senior Coroner for Northumberland v Assistant Coroner for Northumberland [2026] EWHC (Admin) (extempore ruling) 17 June 2026.

Things can go wrong in inquests.  Slip ups and misspeaks are just part of being human. Yet, frustratingly for a coroner, if they want to do the right thing and quickly correct their own innocent mis-statement they will not be able to put things right themselves if the ROI has already been signed making them functus officio (ie their authority to take further steps has expired).

It is then good to learn that what has become known to some as the “Shipsey fix” seems to be working out behind the scenes, even if it is not as yet producing published judgments that might let everyone learn how to use it.  Your blogger only came across the Shipsey fix in action yesterday when a fortuitous listing meant the Divisional Court had listed this case concerning the Northumberland Coroner for an unattended ‘pronouncement’ immediately before her own hearing.

In this Northumberland case an error in the Coroner’s determinations had come to light four days after an inquest concluded.  All involved agreed that the two rogue words ‘family and’ needed to be red lined and struck out from box 3 of the ROI. Happily, the case of Shipsey made clear the High Court has the power to offer this remedy within a s.13 application without the need for a fresh inquest. The Divisional Court was very happy to make that pronouncement yesterday, based on the papers and without the need for any parties’ attendance  the only drawback is that  it took 18 months for that to actually happen. Surely there has to be a better way?

R (O’Brien) v HM Assistant Coroner for Sefton, Knowsley and St Helens [2026] EWCA Civ 605 (19 May 2026) Costs judgment here.

As readers of this blog should already know ‘neutral means neutral’ if you are a Coroner responding to a Judicial Review claim (and if you didn’t know that, see our 2018 blog following the High Court decision in Worthington: here).  Of course in that case the Coroner had ‘succeeded’ in defending the claim, so any judicial comment regarding the payment of costs (even though made by a three judge Divisional Court which included the Chief Coroner) was pure obiter.  Nevertheless the entire Bench had been quite keen to stress that it is really not a very good look for a Coroner to say one thing yet do another.

The Divisional Court in Worthington had sent out a strong message to Coroners that there should be no sleight of hand, saying that: “We do not condone any practice of Coroners … insofar as it exists, of stating that they are taking a neutral stance … but then making submissions that are clearly not neutral but partisan”.  What was made clear in Worthington was that when determining liability for costs what is relevant is the stance the Coroner has actually taken and not the stance the Coroner says they have taken.

If any Coroner might have since thought the High Court didn’t really mean it, then Lord Justice Edis in the Court of Appeal has just taken up a VERY LARGE PINK HIGHLIGHTER to put the matter beyond doubt.

Chief Coroners Guidance for Coroners on the Bench – Updated 10 May 2026 here

A series of updates to the Chief Coroners ‘Bench Book’ have just been published. As the Chief Coroner made clear at its initial publication her Guidance for Coroners on the Bench is intended to be an internet based resource.  Printing a hard copy may not only unnecessarily kill trees but also risks you overlooking the various updates to the ‘Bench Book’ as they come on stream.

One of these updates now deals with the rare (but not wholly exceptional) circumstances of a dispute arising between family members as to whom a body should be released, or how the body should be respectfully disposed of. The updated Guidance proposes that the coroner should first identify if the deceased has made a will and who is the executor of the will. Where there is an executor, the body should be released to the executor to make the appropriate arrangements in accordance with the deceased’s wishes.

Coroners may on occasion need to make a decsion between family factions and the need to avoid delay should be the impetus for coroners doing so. Expediting the funeral having been identified as “the most important consideration” in Hartshorne v Gardner,^[1] indeed the key theme emanating from all the relevant authorities focuses on avoiding delay and ensuring the dignified and decent disposal of the body.

R (O’Brien) v HM Assistant Coroner for Sefton, Knowsley and St Helens [2026] EWCA Civ 499 (22 April 2026) here.

The Court of Appeal has handed down some useful guidance on how to approach the thorny issue of causation in deaths where domestic violence has been a factor and there had been previous contact with police.  At first instance the High Court had held that it would have been  speculative of the Coroner to consider what might have been the position had the perpetrator been arrested before the death: the Court of Appeal did not agree.

In this 17 page judgement Lord Justice Edis guides us all on how to navigate the various “what ifs” associated with the potentially uncertain terrain of the criminal justice process.  Readers may well now be rushing to the latest editions of various criminal sentencing guidelines to navigate this new terrain.