Veronica Robinson, R (on the application of) v HM Assistant Coroner for Blackpool & Fylde

Veronica Robinson, R (on the application of) v HM Assistant Coroner for Blackpool & Fylde

The coroner was justified in finding Article 2 ECHR was not engaged as the circumstances did not fall within automatic categories and there was no arguable breach of the operational duty; the summing up was adequate and the jury was not compelled to return a narrative verdict; the coroner was not irrational in deciding not to make a Prevention of Future Deaths report.

Parties
Claimant: Mrs Veronica Robinson; Defendant: HM Assistant Coroner for Blackpool & Fylde; Interested Party: Chief Constable of Lancashire Police
Jurisdiction
England and Wales
Judgment Date
04 March 2025
Procedural Posture
Judicial Review / Final Judgment
Outcome
Claim dismissed
Legal Topics
Article 2 ECHR, Inquest Procedure, Prevention of Future Deaths Reports, Misadventure Verdict, Police Conduct
Public Law Human Rights Coroners Law Article 2 ECHR Inquest Procedure Prevention of Future Deaths Reports Misadventure Verdict Police Conduct

Case Brief

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Parties

Mrs Veronica Robinson

Claimant

HM Assistant Coroner for Blackpool & Fylde

Defendant

Chief Constable of Lancashire Police

Interested Party

Procedural Posture

Judicial Review / Final Judgment

Legal Issues

  1. 1 Whether Article 2 ECHR procedural obligation was triggered by the circumstances of Mr Robinson's death
  2. 2 Adequacy of the coroner's summing up and directions to the jury
  3. 3 Whether the coroner was required to make a Prevention of Future Deaths report

Ratio Decidendi

The coroner was justified in finding Article 2 ECHR was not engaged as the circumstances did not fall within automatic categories and there was no arguable breach of the operational duty; the summing up was adequate and the jury was not compelled to return a narrative verdict; the coroner was not irrational in deciding not to make a Prevention of Future Deaths report.

Court Disposition

Claim dismissed