Tyrrellv HM Senior Coroner County Durham And Darlington (Rev 1)

Tyrrellv HM Senior Coroner County Durham And Darlington (Rev 1)

The procedural obligation under Article 2 ECHR is not triggered by all deaths in custody; it arises only where there is reason to believe the state may have breached its substantive obligations to protect life. In this case, the death was from natural causes, with no evidence of state failure, so the coroner was...

Source-derived case information.

Parties
Claimant: Zifforah Tyrrell; Defendant: HM Senior Coroner County Durham and Darlington; Interested Party: The Ministry of Justice
Jurisdiction
England and Wales
Judgment Date
26 July 2016
Procedural Posture
Judicial Review / Final Judgment
Outcome
Claim dismissed
Legal Topics
Article 2 ECHR, Procedural Obligation, Deaths in Custody, Middleton Inquest, Natural Causes, State Detention
Human Rights Law Coronial Law Administrative Law Article 2 ECHR Procedural Obligation Deaths in Custody Middleton Inquest Natural Causes +1 more

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Parties

Zifforah Tyrrell

Claimant

HM Senior Coroner County Durham and Darlington

Defendant

The Ministry of Justice

Interested Party

Procedural Posture

Judicial Review / Final Judgment

Legal Issues

  1. 1 Does Article 2 ECHR require a coroner to conduct a Middleton inquest for a prisoner who dies of natural causes in custody?
  2. 2 Is the procedural obligation under Article 2 ECHR triggered by all deaths in custody, regardless of cause?

Ratio Decidendi

The procedural obligation under Article 2 ECHR is not triggered by all deaths in custody; it arises only where there is reason to believe the state may have breached its substantive obligations to protect life. In this case, the death was from natural causes, with no evidence of state failure, so the coroner was correct not to conduct a Middleton inquest.

Court Disposition

Claim dismissed

Orders

  • Judicial review claim dismissed