R (on the application of Wilkinson) v HM Coroner for the Greater Manchester South District  EWHC 2755 (Admin) raised the issue of whether evidence of the commission of the criminal offence of causing death by careless driving (contrary to section 2B of the Road Traffic Act 1988) was capable of justifying a verdict of unlawful killing at an inquest, a question on which there was a divergence of view amongst coroners. Having reviewed the history of the verdict of unlawful killing, the Court observed that it was not known whether the expression “unlawful killing” had been used in the context of inquests prior to 1984 but that if it had there was no suggestion that it extended to any criminal offence other than the three homicide offences of murder, manslaughter or infanticide. The Court concluded that the main purpose of having a verdict of unlawful killing was to distinguish between those cases where there had been an accident of some kind (where someone might still be to blame for it) and those cases where it would be an abuse of language to describe the events leading to death as simply an accident. Causing death by careless or inconsiderate driving should not, the Court ruled, be treated as unlawful killing for the purposes of the conclusion of an inquest. Unlawful killing was restricted to murder, manslaughter (including corporate manslaughter) and infanticide. Bad driving cases causing death should only be regarded as unlawful killing for inquest purposes if they satisfy the ingredients for gross negligence manslaughter.