Where a coroner was conducting an inquest into a death that occurred before the Human Rights Act 1998 came into force, "how" a deceased came by her death for the purposes of the Coroners Act 1988 s.11(5)(b)(ii) was to be considered by reference to the pre-1998 Act test outlined in R v North Humberside and Scunthorpe Coroner, Ex parte Jamieson [1995] 1 W.L.R. 31, so that "how" in s.11(5)(b)(ii) meant "by what means" and not "in what broad circumstances".

[2005] EWHC 833 (Admin)

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