Alexander Lewis-Ranwell v G4S Health Services (UK) Ltd & Ors
[2024] EWCA Civ 138
Natasha Miranda Bryan, R (on the application of) v His Majesty’s Assistant Coroner for Buckinghamshire
12 January 2024
[2024] EWHC 26 (Admin)
High Court
A mother and daughter died when the mother jumped in front of a train. A family member challenged the coroner's decision about the daughter's death, arguing the coroner got the law wrong about mental state and his decision was illogical. The court disagreed, saying the coroner properly considered the evidence and reasonably concluded the mother was likely mentally ill when she acted.
Key Facts
- •Leighane Redmond and her three-year-old daughter, Melsadie, died after Leighane jumped in front of a train with Melsadie in her arms.
- •The inquest was a protracted Article 2 'Middleton' inquest, investigating Leighane's mental state and the circumstances of the deaths.
- •Melsadie's paternal aunt (Ms Bryan) challenged the Coroner's narrative conclusion regarding Melsadie's death.
- •The challenge focused on the Coroner's approach to Leighane's sanity/insanity and the rationality of the narrative conclusion.
- •The Coroner concluded Leighane's death was suicide and Melsadie's death was a narrative conclusion, stating it was not possible to determine that Leighane was not suffering from a disease of the mind that made her incapable of distinguishing right from wrong.
Legal Principles
Purpose of inquest is to ascertain who the deceased was and how, when and where they died (including circumstances in Article 2 inquests).
Coroners and Justice Act 2009, section 5
Coroner must not appear to determine questions of criminal or civil liability.
Coroners and Justice Act 2009, section 10
M'Naghten rules define the test for insanity, with a presumption of sanity in criminal cases.
M'Naghten rules (summarized in Archbold 2024)
Presumptions of sanity/insanity are inapposite in coronial proceedings; the coroner must consider all evidence to determine insanity on the balance of probabilities.
R v HM Coroner for North Humberside, Ex p. Jamieson; R (Maughan) v Coroner for Oxfordshire; R (O’Connor) v Avon Coroner
In coronial inquests, a conclusion of unlawful killing requires proof on the balance of probabilities that death was caused by a criminal offence, but this is not available if the person was insane at the time, lacking mens rea.
Chief Coroner’s Law Sheet No. 1, paragraph 32
Outcomes
Ground 1 (misdirection in law) failed.
The court found that while the Coroner's conclusion wasn't immaculately expressed, he did consider evidence of Leighane's insanity, not starting with a presumption of insanity.
Ground 2 (rationality challenge) failed.
The court found ample evidence to support the Coroner's conclusion that Leighane was likely insane at the time of the act. The irrationality of her actions, coupled with evidence of episodic psychosis, supported this finding.
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