Secretary of State for Foreign and Commonwealth Affairs v Assistant Deputy Coroner for Inner North London: Admn 27 Jun 2013

The coroner was to hold an inquest into the death of Alexander Litvinenko, a prominent Russian exile. The Secretary of State issued a public interest immunity certificate in respect of several documents sought for the inquest, which, in part, the Coroner rejected. The court considered the possibility that a Properly Interested Person should be allowed as interested parties, and whether any proceedings, or part of them might not be held openly.
Held: It was at the court’s discretion within the rules to decide whether a person should be joined as an interested third party in judicial review proceedings. That someone had been accepted as a properly interested person by the Coroner, that does not mean that he need be such on a judicial review.

Judges:

Goldring, Treacy LJJ, Mitting J

Citations:

[2013] EWHC 1786 (Admin), [2013] WLR(D) 261

Links:

Bailii, WLRD, Gazette

Statutes:

Coroners Rules 1984

Jurisdiction:

England and Wales

Citing:

CitedRegina v South London Coroner ex parte Thompson 8-Jul-1982
The court discussed the function of the coroner and his inquest.
Lord Lane CJ said: ‘The coroner’s task in a case such as this is a formidable one, and no one would dispute that; that is quite apart from the difficulties which inevitably arise . .
CitedRegina on the application of Ahmed v HM Coroner South and East Cumbria 2009
Irwin J considered the wide discretion given to Coroners: ‘There is no hard and fast obligation on the part of the Coroner to disclose any witness statements or material: it is a matter of the exercise of discretion.’ . .

Cited by:

See AlsoSecretary of State for Foreign and Commonwealth Affairs v Assistant Deputy Coroner for Inner North London Admn 27-Nov-2013
The SS had claimed public interest immunity (PII) in respect of several documents requested for an inquest into the death of Alexander Litvinenko, a prominent Russian exile. The coroner had rejected the claim for several, and the SS now appealed. . .
Lists of cited by and citing cases may be incomplete.

Coroners, Litigation Practice, Judicial Review

Updated: 10 September 2022; Ref: scu.511224