Since the Human Rights Act 1998 did not apply retrospectively, deaths which occurred before that Act came into force would be investigated in inquests conducted under the prior domestic coronial law; accordingly the jury, although not prohibited from making factual findings directly relevant to the cause of death which might point to criminal, could not return a verdict of unlawful killing.
A coroner was not required to give effect to the investigative obligation under art 2 of the European Convention on Human Rights when holding an inquest into a death which occurred before the Human Rights Act 1998 was implemented on 2 October 2000.