When Public Inquiry meets Inquest

August 13, 2024

Although relatively uncommon, an inquest can be adjourned pending the outcome of a public inquiry. What happens when the public inquiry publishes its findings?

Rule 24 of the Coroner’s (Inquests) Rules 2013 provides:

(1) A coroner may admit the findings of an inquiry, including any inquiry under the Inquiries Act 2005 if the coroner considers them relevant to the purposes of the inquest.

(2) Before admitting such inquiry findings as evidence, the coroner must announce publicly that—

(a)the findings of the inquiry may be admitted as evidence;

(b)the title of the inquiry, date of publication and a brief account of the findings; and

(c)that any interested person is entitled to see a copy of the inquiry findings if he or she so wishes.

The findings and recommendations of the Infected Blood Inquiry were published in May 2024.

Following written submissions from IPs, one area coroner resuming one such inquest determined that the inquest he was dealing with should be dealt with using both r.23 and r.24. No oral evidence was required. The area coroner admitted relevant reports from a consultant hepatologist under r.23 and then went on to admit certain findings from the IBI under r.24. The coroner undertook a filtering exercise to provide the brief account of the findings. The area coroner went on to record a narrative conclusion.

David Sandiford specialises in inquests, high value personal injury and civil police actions. He is regularly instructed in high profile inquests attracting national media attention.