The recent High Court case of R (on the application of Butler) v HM Coroner for the Black Country District explored the appropriate scope of an inquest where Article 2 of the European Convention of Human Rights is not engaged, ie when an inquest is concerned with determining by what means a deceased came by his death and not a consideration of the broad circumstances surrounding the death. It was clear that such an inquest is not limited to the last link in the chain of causation but it was held that the coroner was wrong to direct himself that his powers as to the scope of the inquest were unlimited. The coroner was found to have adopted too wide an approach on this occasion such as to render his decisions regarding evidence unlawful. The coroner’s decisions were set aside and it was ordered that the resumed hearing of the inquest should take place before a different coroner. The case provides a useful example of when a coroner’s decisions can be challenged prior to, and not post, a full inquest hearing.