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Adam Canning v HM Coroner for Northampton

The court had been entitled to uphold a coroner’s decision refusing to hold an inquest into the death of a child where there was no evidence of culpable human failure sufficient to put a properly instructed coroner on notice of the need for further investigation.

4 August 2006

The appellant (C) appealed against the decision that the respondent coroner (N) had been entitled to refuse to hold an inquest into the death of C’s son (F). F had been gravely disabled by severe cerebral palsy, and suffered global neurodevelopmental delay, epilepsy, blindness and deafness. F could only communicate by smiling and laughing, or crying when in pain. On the evening before his death, F had been attending a residential care home. He had lost his appetite and appeared to be unsettled, which was not unusual. The staff gave F paracetamol, as he appeared to be in pain, and thereafter he settled and slept through the night. In the morning, F’s extremities were found to be cold and his lips were cyanosed; he was sent to hospital, but died en route. A postmortem report indicated that F’s death had been caused by an infarction of his small bowel and volvulus. N refused to hold an inquest into F’s death, having found that he had died from natural causes and that there was ...

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