A recent High Court case demonstrates the complexities that can occur further to a successful judicial review of an inquest. The case of R (on the application of) HM Coroner for the Eastern District of London v The Secretary of State for Justice and Susan Sutovic, Velisa Sutovic and Marko Sutovic [2009], explores the diffi culties faced by a coroner who was ordered to carry out a fresh inquest after the original inquest had been successfully challenged by judicial review. The second coroner decided that the body of the deceased needed to be exhumed to complete her enquiries, but this led to all kinds of diffi culties which, in the end, required resolution by way of a judicial decision.