Visit JCPCUKSC/2019/0137
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PUBLIC LAW/HUMAN RIGHTS
R (on the application of Maughan) (AP) (Appellant) v Her Majesty's Senior Coroner for Oxfordshire (Respondent)
Case summary
Case ID
UKSC/2019/0137
Parties
Appellant(s)
Thomas Maughan
Respondent(s)
Her Majesty's Senior Coroner for Oxfordshire
Issue
Is the applicable standard of proof in inquest proceedings in the case of suicide the balance of probabilities (the civil standard) or beyond reasonable doubt (the criminal standard)?Does the answer depend on whether the determination is expressed as a short-form conclusion or a narrative conclusion?
Facts
James Maughan, the appellant’s brother, was a prisoner held in HMP Bullingdon. On 11 July 2016, James Maughan was found hanging in his cell. He was pronounced dead shortly afterwards. At the subsequent inquest into his death, the Senior Coroner invited the jury to consider a narrative verdict to the effect that James Maughan committed suicide on the balance of probabilities. The jury returned a narrative conclusion finding that it was more likely than not that James Maughan had committed suicide.The appellant began judicial review proceedings challenging the jury’s determination and arguing that the Senior Coroner erred in law in instructing the jury to apply the civil standard of proof when considering whether the deceased had killed himself. The Divisional Court dismissed the application for judicial review, concluding that the standard of proof in all suicide conclusions is the civil standard. The appellant appealed that decision to the Court of Appeal, which upheld the Divisional Court’s judgment. The appellant appealed to the Supreme Court
Date of issue
31 May 2019
Judgment appealed
Judgment details
Judgment date
13 November 2020
Neutral citation
[2020] UKSC 46
Judgment links
Judgment summary
13 November 2020
Appeal
Justices
Hearing dates
Full hearing
Start date
26 February 2020
End date
27 February 2020
Watch hearings
26 February 2020 - Morning session
26 February 2020 - Afternoon session
27 February 2020 - Morning session
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Last updated 16 April 2024