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‘Elementary, my dear Watson’: The duty to investigate in article 2 inquests

Matthew Waszak discusses a recent case on the scope of coroners' investigative duties in an inquest into a death in police custody

23 February 2016

In R (on the application of Maureen Speck)
v HM Coroner for District of York [2016] EWHC 6 (Admin), handed down on 12 January 2016, Mr Justice Holroyde, with whom Sir
Brian Leveson agreed, held that a coroner's investigative duty under section 5 of the Coroners and Justice Act (CJA) 2009 in an article 2 inquest is limited to matters which caused, or at least arguably appeared to have caused or contributed to, the deceased's death.

Miss Toni Speck died while in police custody at Fulford Road Police Station in York on 2 June 2011. She suffered from a history of psychiatric illness and had, on a number of previous occasions, been admitted into a psychiatric hospital in York.

That afternoon, concerned members of the public had alerted patrolling police officers after Miss Speck was seen behaving erratically in the street. She was detained by one of the officers under section...

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