Canning v HM Coroner for the County of Northampton

Canning v HM Coroner for the County of Northampton

The coroner’s refusal to hold an inquest was not irrational or unlawful. The evidence did not establish reasonable cause to suspect culpable human failure leading to an unnatural death. The expert evidence did not go beyond suggesting lack of prudence, and did not establish culpability. Article 2 ECHR did not require an inquest on these facts.

Parties
Claimant/applicant: Adam Wilkie Canning; Defendant/respondent: HM Coroner for the County of Northampton
Jurisdiction
England and Wales
Judgment Date
25 July 2006
Procedural Posture
Civil Appeal / Appeal From Divisional Court to Court of Appeal
Outcome
Appeal dismissed
Legal Topics
Coroner's Inquest, Unnatural Death, Judicial Review, Article 2 ECHR, Standard of Review (wednesbury)
Administrative Law Coroners Law Human Rights Coroner's Inquest Unnatural Death Judicial Review Article 2 ECHR Standard of Review (wednesbury)

Case Brief

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Parties

Adam Wilkie Canning

Claimant/applicant

HM Coroner for the County of Northampton

Defendant/respondent

Procedural Posture

Civil Appeal / Appeal From Divisional Court to Court of Appeal

Legal Issues

  1. 1 Whether the coroner's refusal to hold an inquest was irrational or unlawful under section 13(1) of the Coroner’s Act 1988
  2. 2 Whether there was reasonable cause to suspect an 'unnatural' death due to culpable human failure
  3. 3 Whether Article 2 of the Human Rights Convention required an inquest

Ratio Decidendi

The coroner’s refusal to hold an inquest was not irrational or unlawful. The evidence did not establish reasonable cause to suspect culpable human failure leading to an unnatural death. The expert evidence did not go beyond suggesting lack of prudence, and did not establish culpability. Article 2 ECHR did not require an inquest on these facts.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed; no order for an inquest