The recent case of R (on the application of Carol Pounder) v HM Coroner for North and South Districts of Durham & Darlington (2010) explored the circumstances when a Coroner would have to recuse himself from presiding over a fresh inquest. The case concerned the death of a 14 year old boy who had taken his own life in his cell at a secure training centre hours after having been physically restrained. At the original inquest, the Coroner declined to rule on whether the restraint was lawful. On judicial review of that decision, it was held that a fresh inquest was appropriate as the issue of the force used during the restraint, and the question of whether the restraint was lawful, were clearly relevant. However, at a pre-inquest hearing, the same Coroner found it was appropriate for him to hear the resumed inquest. The High Court disagreed with the Coroner’s decision, fi nding that the Coroner had already committed himself to a particular factual outcome on an issue of “real importance” to the enquiry. As a result “a fair-minded and informed observer having considered the facts” would conclude that there was a possibility of bias.