Prevention of Future Deaths reports · 2022

Ketheeswaren Kunarathnam

Regulation 28 report to prevent future deaths, reference 2022-0030, written 26 Jan 2022. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report26 Jan 2022
Reference2022-0030
DeceasedKetheeswaren Kunarathnam
CoronerLydia Brown
Coroner areaWest London
CategoryState Custody related deaths · Mental Health related deaths · Suicide (from 2015) · Other related deaths
Sourcejudiciary.uk record · original PDF
Responses published1

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

REGULATION 28: REPORT TO PREVENT FUTURE DEATHS 

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO: 

1. The Home Office

1 

CORONER 

I am Lydia Brown Acting Senior Coroner, for the Coronial area of West London 

2 

CORONER’S LEGAL POWERS 

I make this report under paragraph 7, Schedule 5, of the Coroners and Justice Act 2009 
and Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013.  

3 

INVESTIGATION and INQUEST 

On  23rd  February  2018  I  commenced  an  investigation  into  the  death  of  
Ketheeswaren KUNARATHNAM . The investigation concluded at the end of the 
inquest on 10th December 2021. The conclusion of the inquest was 

Medical cause of death 
1a Hanging 

Conclusion 
  Suicide 

There were shortcomings from all organisations. Healthcare did not carry out 
their daily checks, prison officers did not carry out their conversations, as set 
in the Assessment, Care in Custody and Teamwork document. Immigration 
Officers  did  not  attend  to  Mr  Kunarathnam's  requests  in  good  time, 
particularly in the weeks leading up to his death. The Immigrations Officers 
did not take into account Mr Kunarathnam's specific needs. He did not take 
bad news well and reacted badly to it. This wasn't always  factored in when  
dealing with him and his particular worries surrounding his immigration. The 
Assessment, Care  in  Custody and  Teamwork  document was  not always 
carried out effectively by all staff. For example, dates and times were missed 
while Mr Kunarathnam  was in  Wormwood Scrubs Prison. If conversations 
took place, they were not always recorded. Comments and discussions were 
not explicit, ad comments had no framework and remained unstructured. A 
lack of training and resources played a part. All agencies worked on different 
operating systems and records, the lack of communication, basic training and 
resources made  it  challenging  for  them  to  work  as  one  cohesive  unit. 
Significant  staff  workload  contributed  to  the  issues  around  affective 
communication and recordkeeping 

4 

CIRCUMSTANCES OF THE DEATH 

After being tortured in Sri Lanka,  Mr Kunarathnam  was  given indefinite leave to 
remain  as  a  refugee in  the  United  Kingdom.  He  was  detained  on  the  sixth 
September 2017 at Her Majesty's Prison Wormwood Scrubs in West London. Mr 
Kunarathnam  was  detained  for 28  days.  Following this  he  was  kept in  further 
detention by the Home Office due to a  deportation order. After completing his 28 

1 

 day  sentence, there were alternative pathways  at  every stage, and  the relevant 
agencies did not fully explore these. Mr Kunarathnam was not managed when he 
was  on an  assessment, care in custody and teamwork document by the multiple 
agencies responsible for his  care, There was  evidence of poor record keeping, 
communication  and  untimely  responses.  There  was  a  failure  to  follow  prison 
procedural systems.  High  staff workload appeared  to  play  a  crucial  factor. The 
prison did monitor Mr Kunarathnam early in his stay and records state this. A pattern 
of food refusal is evident and not considered later in his detainment. At this point, 
the introduction of a food refusal log should have been appropriate, given the history 
- a  failure on a multi agency level. The prison staff didn't appropriately review his 
mental health. For example, according to the mental health team, multiple prison 
stays, under different names meant that Mr Kunarathnam's records were not easy 
to find. Records were lept but often not shared with others at the correct time. The 
core  failure  is  communication 
for  several  reasons:  one  includes  patient  
confidentiality.  It  meant  that  non-health  professionals  were  not  party  to  Mr 
Kunarathnam's entire and current medical state. The mental health team mentioned 
that Mr Kunarathnam was an 'impulsive ma who reacts badly to information he finds 
distressing'. His considered actions, often coupled with impulsive behaviour, sent 
mixed messages to the parties involved - including his mentions of suicide and food 
refusal. Mr Kunarathnam had made a bail application. A Home Office representative 
recognised that information on it could form the basis  for an asylum  application. 
Nothing  in  writing  or  on  record  suggests  that  anyone  from  the  Home  Office 
discussed this  with Mr  Kunarathnam.  It  is  not  entirely clear  to  the  Jurors if  Mr 
Kunarathnam  had  all  the information he needed to make  an  asylum  application. 
Regarding bail, his immigration status and rights of appeal, Mr Kunarathnam was 
kept informed by being invited to  Assessment, Care  in  Custody and  Teamwork 
reviews and paperwork delivered to his cell. It is unclear whethe r the Home Office 
carried out the required reviews and as such vague whether they would assess any 
risk.  

On the twenty third of February 2018 Mr Kunarathnam was found hanging in his cell 
at Her Majesty's Prison Wormwood Scrubs. 

5 

CORONER’S CONCERNS 

During the course of the inquest the evidence revealed matters giving rise to concern. In 
my opinion there is a risk that future deaths could occur unless action is taken. In the 
circumstances it is my statutory duty to report to you. 

The MATTERS OF CONCERN are as follows. – 

During the inquest it became apparent that a certain number of prisoners in HMP 
Wormwood Scrubs were detained for deportation reasons after the conclusion of their 
prison sentence.  There seemed to be a marked disparity between the information and 
advice available to a detained prisoner, compared with a free individual or one in a 
deportation centre.  There was a paucity of available information and the letters sent out by 
the Home Office were written in legal English with no offer of translation or “plain English” 
assistance.  Individuals in the community could access the internet, Law centres, citizens 
advice or any other sources of assistance that were not available to detained prisoners 
due to the restrictive regime, putting them at a disadvantage. 

Communication between the prison officers and home office officials and immigration staff 
was inef fective and frequently not evidenced at all.  Pieces of paper were lost, phones 
were unanswered with no answer phone facility, email addresses were unavailable due to 
incompatible systems and there was no audit trail of attempted communications or the 
reason why these were unsuccessful.  Many requests made by or on behalf of the prisoner 
were not dealt with in a timely manner or at all. 

2 

 
 
 
 
 
 
 
 
 
 
 6 

ACTION SHOULD BE TAKEN 

In my opinion action should be taken to prevent future deaths and I believe you and 
your organisation have the power to take such action. 

7 

YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date of this report,  

namely by 22nd March 2022 I, the coroner, may extend the period. 

Your response must contain details of action taken or proposed to be taken, setting out 
the timetable for action. Otherwise you must explain why no action is proposed. 

COPIES and PUBLICATION 

I have sent a copy of my report to the Chief Coroner and to the following Interested 
Persons  

 – Partner of the deceased 

1. 
2. 
3.  Barnet, Enfield and Haringey MHS NHS Trust 
4.  Home Office Immigration  
5.  Practice Plus Group 

 – Bhatt Murphy Solicitors 

I am also under a duty to send a copy of your response to the Chief Coroner and all 
interested persons who in my opinion should receive it. 

I may also send a copy of your response to any other person who I believe may find it 
usef ul or of interest. 

The Chief  Coroner may publish either or both in a complete or redacted or summary 
f orm. He may send a copy of this report to any person who he believes may find it useful 
or of  interest. 

You may make representations to me, the coroner, at the time of your response, about 
the release or the publication of your response. 
Signed  

Dated 26th January 2022 

HM Acting Senior Coroner West London Jurisdiction 

3

Responses

1 response published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from Home Office (PDF)
Tom Pursglove MP 
Minister for Justice and Tackling Illegal 
Migration 

2 Marsham Street 
London SW1P 4DF 
www.gov.uk/home-office 

Lydia Brown 
Acting Senior Coroner – West London Jurisdiction 
Coroner’s Court 
25 Bagleys Lane 
Fulham 
London, SW6 2QA 

Dear Ms Brown, 

MR KETHEESWAREN KUNARATHNAM  
 REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

22 March 2022 

Thank you for your Regulation 28 report, dated 26 January 2022, following the inquest into 
the death of Mr Ketheeswaren Kunarathnam. I am grateful to you for sharing your findings, 
and for the opportunity to reflect on the processes that were in place around the time of Mr 
Kunarathnam’s  detention  in  2018.  I  am  sorry  to  learn  of  Mr  Kunarathnam’s  passing  and 
would like to express my condolences to his friends and family.   

I can assure you that the Home Office takes the health and welfare of people detained under 
immigration powers very seriously. The concerns you have identified have been carefully 
considered  by  officials.  This  response  summarises  the  action  taken  to  address  these 
concerns where they pertain to the Home Office. I also hope it will be useful to set out some 
wider reforms which impact on the detention of foreign national offenders (FNOs) as well as 
those actions taken following the death of Mr Kunarathnam in HMP Wormwood Scrubs.  

Concern 1 – Disparity between information and advice available depending on where 
the person was detained or within the community  

We make every effort to ensure that an FNO’s removal by deportation coincides, as far as 
possible, with their release from prison on completion of sentence. Where it is not possible, 
careful consideration is given on a case-by-case basis as to whether immigration detention 
is appropriate and justified. There is a presumption in favour of liberty for all individuals and 
decisions to detain are made in line with published guidance. A timely risk assessment is 
also  carried  out  which  reviews  whether  that  person  is  suitable  to  be  transferred  into 
Immigration  Removal  Centres  (IRCs)  while  detained.  This  transfer  decision  may  also  be 
further considered at subsequent points during detention.   

The  Home  Office  and  HM  Prison  and  Probation  Service  (HMPPS)  recognised  that  there 
were  some  disparities  between  those  detained  under  immigration  powers  in  IRCs  and 
prisons. That is why a targeted project was initiated in 2019 to take forward work to bring 
parity where possible in the treatment of, and safeguards provided to, those detained under 
immigration  powers.  HMPPS  are  currently  considering  aspects  of  this  work  and  a 
consultation on some elements is understood to be set to commence in Spring 2022.   

 In your report, you specifically highlighted an inability to access the internet, Law Centres, 
Citizens  Advice  or  any  other  sources  of  assistance  for  those  detained  in  a  prison.  We 
recognise  that  not  all  FNOs  will  be  legally  represented  and  therefore  throughout  the 
deportation  process  we  will  seek  to  explain  and  signpost  appropriately  whether  through 
written  documents  or  direct  engagement.  The  deportation  notice  informs  the  FNO  why 
deportation  is  being  considered  and  invites  the  person  to  provide  any  reasons  why  they 
consider it should not be pursued. A statement of reasons accompanies this decision, clearly 
setting out examples of possible claims, including those protection and human rights based, 
which  could  be  raised  alongside  possible  sources  of  supportive  evidence.  These  notices 
signpost Civil Legal Advice (and Scottish and Northern Ireland equivalents); an organisation 
which  can  provide  information  on  legal  aid  if  a  person  is  unable  to  pay  for  a  legal 
representative. A published list of legal aid providers is available from the Legal Services 
Commission.  Removal  paperwork  reminds  the  person  of  the  same.  Additionally,  in 
November 2021, HM Prisons and Probation Service (HMPPS) issued an instruction which 
allows all individuals held under immigration powers in a prison, access  to 30 minutes of 
legally aided immigration legal advice. This provides a functional equivalent to the service 
currently available in IRCs.  

All  persons  detained under immigration  powers, irrespective  of  their  location,  are notified 
that they can apply to the courts, at any time, for bail. The application forms for immigration 
bail for all detained individuals in prison have now been translated into the 18 most common 
languages  to  ensure  individuals  can  be  effectively  signposted.  Use  of  an  interpretation 
service  is  sometimes  available  for  deportation  matters  depending  on  the  language 
proficiency of the FNO.  

We  have  considered  the  concerns  you  have  raised  as  to  the  effectiveness  of  in  person 
engagement  with  immigration  officials  in  Mr  Kunarathnam’s  case.  The  Home  Office 
understands that in person contact with individuals subject to deportation action is hugely 
important. A dedicated team of immigration officers embedded in the prison estate carry out 
that engagement and endeavour to induct an FNO soon after they arrive at a prison. This 
induction  seeks  to  explain  the  deportation  process,  obtain  basic  person  details  and  any 
vulnerabilities or medical conditions. The induction process is periodically reviewed, and the 
interactions  are  now  recorded  and  accessible  to  other  Home  Office  officials  on  internal 
databases.  FNOs  can  also  request  to  speak  with  an  immigration  officer  on  an  individual 
basis via a wing application that is lodged with the prison’s wing office which is then passed 
to the embedded Immigration Prison Teams.  

Concern 2 - Communication between officials from the Home Office and HM Prison 
and Probation Service (HMPPS) 

The  Home  Office  is  committed  to  a  collaborative  relationship  with  HMPPS  in  the 
management of persons subject to deportation action both during their custodial sentence 
and  if  detained  in  a  prison  following  completion.  Regular  bilateral  meetings  between  the 
Home Office and stakeholders at various levels support this closer working relationship and 
allow for opportunities for joint working to be effectively highlighted.   

At  a  local  level,  the  Home  Office’s  Immigration  Prison  Team  (IPT)  embedded  at  HMP 
Wormwood Scrubs now works very closely with prison colleagues, with established lines of 
communication and regular meetings between the two parties around vulnerable persons. 
Since 2018, IPT have also been working with individual prisons across the country to ensure 
the attendance of Home Office officials at all Assessment Care in Custody and Teamwork 
(ACCT)  reviews  so  that  updates  on  case  progression  can  be  provided  and  information 
effectively exchanged.  

 
 
  
 
 
 
 
 You concluded that an individualised assessment of Mr Kunarathnam’s needs did not take 
place when relaying immigration matters. I would like to assure you that officials recognise 
it is paramount to consider the individual circumstances of a FNO and their  vulnerabilities 
when serving immigration notices. This routinely takes place in prisons across the country 
where  FNOs  are  serving  their  sentences.  Immigration  Officers  will  make  the  relevant 
Offender Manager Unit and Wing Offices aware when serving immigration notices to ensure 
the  FNO  can  access  support  if  required.  This  will  also  be  recorded  on  Home  Office 
databases  for  other  officials  to  view.  A  further  line  of  assurance  is  provided  by  monthly 
meetings  with  senior  immigration  officers  to  discuss  vulnerable  cases  and  take  forward 
actions in our hub prisons.  

Communications are also more appropriately documented. Immigration officers embedded 
in prisons now ensure all conversations are recorded and where appropriate signed by the 
FNO. Digitalisation improvements have allowed for engagements with FNOs to be raised on 
internal databases along with any vulnerability concerns promptly after interactions, while 
Immigration  Officers  have  access  to  a  Ministry  of  Justice  system,  to  ensure  immigration 
contact  and  records  are  widely  shared.  At  HMP  Wormwood  Scrubs,  immigration  officers 
now have access to the HMPPS database where relevant information is also accessible. To 
further strengthen collaborative working an FNO Information Hub has been launched which 
will pave the way for a digital platform and sharing forum for both Home Office and HMPPS 
users  which  aims  to  provide  signposting  resources  to  prepare  FNOs  for  their  release  or 
removal. We will continue to review where further technological improvements can be made 
to ensure the timely and secure exchange of information between itself and prison officials.   

We recognise the benefit of improving a mutual understanding of relevant processes to both 
departments in our aim to work more cohesively. Therefore, awareness sessions have been 
provided at our hub prisons providing an overview of the deportation process, the service of 
immigration notices and the work of our immigration officers.   

More  broadly  reforms  to  immigration  detention  have  increased  the  scrutiny  of  such 
decisions. Once a person is detained, regular reviews are undertaken. The decision and the 
rationale  for  ongoing  detention  or  alternatively  notification  for  release,  is  also  routinely 
shared with the person. Vulnerabilities are monitored in accordance with the Adults at Risk 
Policy (AAR) and reviewed at routine intervals. Case Progression Panels act as an internal 
assurance mechanism to ensure the appropriate progression of all persons detained under 
immigration powers. Since these were introduced in 2017, several improvements have been 
made  to  strengthen  the  review  of  case  progression,  vulnerability  and  public  protection 
considerations.  More  recently  this  has  also  included  the  mandatory  attendance  of  an 
independent  panel  member.  Where  barriers  to  removal  are  identified  these  will  be 
considered by the panel in their discussions and recommendations.  

Since 2018 there has been a significant focus on upskilling officials engaged in detention 
through the introduction of mandatory training which focuses on maintaining best practice 
and keeps vulnerability at the forefront of detention decisions. Front-line immigration officers 
in  prisons  also  attend  Self  Harm  Awareness  Sessions  run  by  HMPPS  to  improve  their 
knowledge of dealing with individuals in prison who may be more susceptible to self-harm. 
Additionally, the immigration team who operate within HMP Wormwood Scrubs have also 
received  Assessment  Care  in  Custody  and  Teamwork  training  to  supplement  the  wider 
vulnerability knowledge, as have other Immigration Prison Teams. Although you have found 
this  unfortunately  did  not  occur  in  Mr  Kunarathnam’s  case,  immigration  officers  will 
frequently respond to requests from vulnerable persons, and where relevant identify a claim 
for asylum including taking the necessary steps to lodge the claim and progress it in good 
time by arranging interviews. The Assessment Care in Custody and Teamwork documents 
would also be updated if relevant to the individual.  

 
 
 
 
 
 This  Department  is  committed  to  learning  lessons  to  prevent  future  deaths  of  persons 
detained  under  immigration  powers  and  will  to  explore  any  further  improvements  and  is 
monitoring  compliance.  I  hope  that  the  information  provided  addresses  your  concerns 
satisfactorily.  

Yours sincerely,  

Tom Pursglove MP 

Minister for Justice and Tackling Illegal Migration

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