Coroner – Inquest. The Court of Appeal, Civil Division, held that any deprivation of liberty resulting from the administration of life-saving treatment fell outside art 5(1) of the European Convention on Human Rights, provided it was rendered unavoidable as a result of circumstances beyond the authorities' control, was necessary to avert a real risk of serious injury or damage and was kept to the minimum required for that purpose. Accordingly, there had been no error in the defendant coroner's decision not to hold an inquest into the death of the claimant's sister without a jury.