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.
The background
The Claimant’s elderly mother had died in hospital. Her son alleged significant failings in her medical care relating to hydration, medication management and communication. He maintained that those failings caused her death and amounted to gross negligence manslaughter.
The Trust had admitted a series of failures in the care provided but these were largely related to record keeping, communication and the failure to follow the standard procedure for a mental capacity assessment. However these shortcomings did not appear to have contributed to the death which had been as a result of congestive heart failure, valvular disease, atrial fibrillation, diabetes and frailty.
The Claimant had asked the coroner to investigate on the basis that the death was “unnatural”. Following enquiries with the hospital, the Coroner concluded that as the death was natural and that there was no evidence that suspected failings had contributed to the death, the duty to investigate under s.1 CJA 2009 did not arise.
Over a year later, the Claimant reported the matter to GMP as an alleged case of gross negligence manslaughter and also pursued complaints with the GMC as the independent regulator of doctors. The GMC did not express any concerns in connection with the treatment provided. The GMP declined to investigate, taking the view that the matter should first proceed through the coronial and regulatory processes. Following complaints and review, the force maintained that position. The Claimant challenged that decision by judicial review.
The decision
In upholding GMP’s decision, Coppel J held that it was “legitimate, indeed sensible” for the police to adopt a cautious approach and decide not to embark immediately upon a complex investigation into medical treatment when the “expert bodies” with greater expertise either had already considered the matter or were doing so.
The judge regarded the fact that the Coroner had not reported any concern regarding the death as providing support for a “wait and see” approach. GMP was entitled to take comfort from the fact that neither the regulator nor the Coroner had identified matters suggesting criminal conduct.
The judge emphasised that GMP had not abdicated its functions. The force remained free to revisit the position if new information emerged. But the police were not expected to don a white coat, seize the medical notes and start diagnosing when those with the relevant statutory and clinical expertise had already reviewed the case and seen nothing of concern.
Comment
For coroners, the principal significance of Przybys is its recognition of the influence that coronial decision-making may have on parallel investigative processes.
The judgment confirms that where a coroner has considered the circumstances of a healthcare death and identified no basis for further investigation or police involvement, a police force may legitimately take that fact, and the expertise of a coroner, into account when deciding whether they should launch a gross negligence manslaughter investigation.
Footnotes
[1] R (Secretary of State) v HM Senior Coroner for Norfolk & another [2016] EWHC 2279 (Admin) and see our earlier blog here