Automated Summary
Key Facts
The Supreme Court case R (on the application of Maughan) v Her Majesty's Senior Coroner for Oxfordshire (2020) UKSC 46 concerns the standard of proof required for suicide conclusions in coroner's inquests. The case arose from the inquest into the death of Mr. James Maughan, who was found hanging in his prison cell on 11 July 2016. The appellant argued that the criminal standard of proof (beyond reasonable doubt) should apply to short form suicide conclusions, while the respondent (the Chief Coroner) and intervener (INQUEST) argued for the civil standard (balance of probabilities). The Supreme Court, with Lady Arden delivering the judgment (with Lord Wilson agreeing), held that the standard of proof for all short form conclusions at an inquest is the balance of probabilities, rejecting the argument that a higher standard should apply to suicide conclusions. The judgment was delivered on 13 November 2020.
Issues
The legal issue regarding the standard of proof required for a short form conclusion of suicide in coroner's inquests, specifically whether it should be the criminal standard of proof (beyond reasonable doubt) or the civil standard (balance of probabilities), and whether this standard should apply equally to short form and narrative conclusions.
Holdings
The Supreme Court held that the standard of proof for all short form conclusions at an inquest is the balance of probabilities. The Court dismissed the appeal, ruling that the criminal standard of proof should not be applied to short form conclusions of suicide or unlawful killing. The Court reasoned that this approach is consistent with the general rule for civil proceedings, aligns with the purpose of inquests as fact-finding exercises, and avoids internal inconsistencies within the inquest process. The Court also extended this ruling to unlawful killing, holding that the civil standard should apply to both suicide and unlawful killing short form conclusions.
Legal Principles
The Supreme Court held that the civil standard of proof (balance of probabilities) should apply to all short form conclusions in coroner's inquests, including suicide and unlawful killing. This aligns with the purpose of inquests as fact-finding exercises, not criminal proceedings, and is consistent with the general rule for civil proceedings.
Precedent Name
- Scholes
- In re B
- Middleton
- In re H
- Ex p McCurbin
- Ex p Gray
- Braganza
Cited Statute
- Coroners and Justice Act 2009
- Coroners (Inquests) Rules 2013, rule 34
- Coroners and Justice Act 2009, section 45
Judge Name
- Lord Wilson
- Lady Arden
- Lord Kerr
- Lord Carnwath
- Lord Reed
Passage Text
- 96. A common standard applying to both unlawful killing and suicide is more consistent with principle and removes an inherent inconsistency in the determinations made at an inquest. It reflects the general rule for the standard of proof in civil proceedings.
- 88. The upshot is, in my judgment, that the decision in Ex p Evans is to be overruled. The reasoning in Ex p Gray (in so far as it relates to suicide) and the dictum of Woolf LJ in Ex p McCurbin with regard to suicide are not to be followed. The standard of proof to be applied at an inquest where an issue of suicide arises is in all respects, and whether for the purposes of a short-form conclusion or for the purposes of a narrative conclusion, the civil standard of proof: that is to say, by reference to the balance of probabilities.