Canning v Northhampton County Coroner

Canning v Northhampton County Coroner

There is sufficient prospect of success on appeal regarding whether the coroner should have held an inquest, particularly in light of potential systemic failures and Article 2 ECHR obligations, to justify granting permission to appeal.

Parties
Claimant/applicant: Adam Wilkie Canning; Defendant/respondent: HM Coroner for the County of Northampton
Jurisdiction
England and Wales
Judgment Date
23 March 2006
Procedural Posture
Judicial Review/appeal / Application for Permission to Appeal From Divisional Court to Court of Appeal
Outcome
Permission to appeal granted
Legal Topics
Inquests, Natural Vs Unnatural Death, Article 2 ECHR, Judicial Review of Coroner's Decision

Case Brief

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Parties

Adam Wilkie Canning

Claimant/applicant

HM Coroner for the County of Northampton

Defendant/respondent

Procedural Posture

Judicial Review/appeal / Application for Permission to Appeal From Divisional Court to Court of Appeal

  1. 1 Whether the coroner erred in refusing to hold an inquest into the death of Francis Canning
  2. 2 Whether there was a prima facie case of culpable human failure leading to an unnatural death
  3. 3 Whether Article 2 of the Human Rights Convention was breached by not holding an inquest

Ratio Decidendi

There is sufficient prospect of success on appeal regarding whether the coroner should have held an inquest, particularly in light of potential systemic failures and Article 2 ECHR obligations, to justify granting permission to appeal.

Court Disposition

Permission to appeal granted

Orders

  • Appeal granted
  • Permission to rely on further evidence (Dr Milla) adjourned