R (on the application of Maughan) v HM Senior Coroner for Oxfordshire
[2020] UKSC 46
Ratio Decidendi
The standard of proof for all conclusions at an inquest, including short-form conclusions such as suicide and unlawful killing, is the civil standard (balance of probabilities), not the criminal standard (beyond reasonable doubt).
ਤੱਥ
James Maughan died in HMP Bullingdon. His family sought a conclusion of suicide at the inquest. The coroner directed the jury that the standard of proof for a conclusion of suicide was the criminal standard (beyond reasonable doubt), following the traditional approach. The jury returned a narrative conclusion but did not find suicide. The family challenged the standard of proof applied.
ਫੈਸਲੇ ਦਾ ਸਾਰ
The Supreme Court (Lady Arden giving the lead judgment) held by a 3-2 majority that the civil standard of proof (balance of probabilities) applies to all conclusions at an inquest, including suicide and unlawful killing. This departed from the long-standing practice of applying the criminal standard to these conclusions. The Court reasoned that the Coroners and Justice Act 2009 made no distinction between the standard of proof for different conclusions, and that an inquest is a fact-finding inquiry, not a criminal trial.
ਮੁੱਖ ਹਵਾਲੇ
"An inquest is an inquisitorial fact-finding exercise and not a criminal trial. There is no logical reason why one standard of proof should apply to a narrative conclusion and a different standard to a short-form conclusion."
— Lady Arden
ਬਾਅਦ ਦਾ ਇਲਾਜ
Now the leading authority on the standard of proof at inquests. All conclusions, including suicide and unlawful killing, are determined on the balance of probabilities.