AC-2024-LON-003241 - [2025] EWHC 3014 (Admin)

Fecha: 17-Nov-2025

The Ruling

The Ruling

42.

The Coroner prepared a written ruling which she began delivering at 4pm on 25 March. In the summary which follows, I have given paragraph references to the written Ruling.

43.

The Coroner summarised the relevant provisions of s.5 of the 2009 Act [4], and she referred to the judgments of Haddon-Cave J in the Eastern District of West Yorkshire case and of the Divisional Court in B50 when setting out the test she intended to apply ([6]-[7]). Having referred to the Galbraith-Gailbraith plus debate, the Coroner said that she intended to apply Lord Lane CJ’s test in Galbraith itself ([8]), stating:

“I am aware that Galbraith Plus can be applicable to the coronial jurisdiction, but the application of the Galbraith Plus test will rarely lead to a different outcome to that of classic Galbraith analysis”.

44.

The Coroner also set out the test in Osman, [116], to which all parties in the Inquest had referred throughout ([9]). She then stated ([12]):

“Three key issues were identified as being within the scope of this inquest.
Firstly, whether the Metropolitan Police Service deliberately notified Paul Asbury and/or others of the whereabouts of Mark Williams.
Secondly, whether the Metropolitan Police Service inadvertently notified Paul Asbury and/or others of the whereabouts of Mark Williams.
Whether the Metropolitan Police Service knew or ought to have known that an attack would or might take place and whether steps could or should have been taken to prevent it”.

45.

The Coroner dealt with the first two issues relatively briefly, holding that, applying the conventional Galbraith test, the first two issues could not properly be put to the Jury ([14]-[17]). There is no challenge to that part of her ruling.

46.

The third was dealt with at much greater length. I do not propose to set out the Coroner’s consideration of the issue in full, but to identify only those parts of the ruling relevant to the test she applied, or to demonstrate the conclusion reached:

The Coroner noted that “my role is to apply the law to the facts of this inquest, and to rule whether there is sufficiency of evidence to leave anything other than a short form conclusion to the jury” ([24]).

ii)

The Coroner addressed the evidence under six headings which had featured in CTI’s submissions (see [37(vi)] above), being the six issues which, if the evidential threshold was met, would be left to the Jury for narrative verdicts.

iii)

There was clearly “a risk to the life of Sabina Rizvi”, and that sufficiency of evidence was established on that issue ([28]).

iv)

There was “sufficient evidence that there existed in reality a real and immediate risk to the life of Sabina Rizvi” and that this risk came from Paul Asbury and his associates ([29]-[30]).

There was “insufficient evidence on which a jury could properly find that it was risk of which any police officer was or should have been aware” ([45]).

vi)

If there was no risk “of which any officers were or ought to have been aware, then there is no basis on which the jury properly directed could properly find that there were steps the police should have taken to protect Sabina” ([46]).

vii)

The evidence that the police offered Mark Williams a life in an unmarked car, and extended that offer to Sabina Rizvi, did not “provide enough to engage Article 2 ” ([48]).

viii)

A jury properly directed could not regard the involvement of SO19, the Police specialist firearms unit, as “a reasonable step that ought to have been taken in this matter given the resources involved” ([52]).

ix)

“It would not be open to a jury to conclude that a risk assessment ought to have taken place” ([52]).

“The evidence I have heard at this inquest is insufficient such that a properly directed jury could find that the police were or ought to have been aware of any immediate risk to Sabina Rizvi’s life from Paul Asbury, and there is insufficient evidence to support the suggestion that that the police were or ought to have been aware of such a risk from any quarter” ([55]).

xi)

“There is insufficient evidence that there were steps the police could reasonably have been expected to take to prevent any risk to Sabina from materialising, and therefore there is no evidence that the police failed to take such steps” ([56]).

xii)

“I do not in these circumstances consider it necessary or appropriate to make findings as to causation” ([56]).

47.

At that point the Coroner gave the represented parties an opportunity to consider her Ruling (it being 16.50pm when the reading of the Ruling finished).

48.

Mrs Rizvi sought advice from the counsel team representing the family at the Inquest on the prospects of bringing a judicial review challenge to the Ruling and the advice was negative.

49.

On 26 March, Mrs Rizvi’s counsel team applied to adjourn the Inquest for two to three weeks, putting jury deliberations on hold in the interim, to allow the family to obtain a second opinion. The Coroner refused the application.

50.

That day, the Jury returned a short-form verdict of unlawful killing.