John Wrigley

IN THE MATTER OF: John Wrigley (deceased) – incident at Darley Moor Circuit 3 May 2021 

And 

IN THE MATTER OF: Regulation 28 Report to prevent future deaths dated 29 September 

2023 

RESPONSE OF MOTORSPORT UK ASSOCIATION LIMITED (‘MOTORSPORT UK’) 

1.  This  is  the  Response  of  Motorsport  UK  to  the  Regulation  28  Report  dated  29 

September 2023 under the hand of Ms Sabyta Kaushal, HM Assistant Coroner Derby 

& Derbyshire (‘HMC’) (‘the Report’). The Report was addressed to 

Both are senior members of staff at Motorsport UK. 

 and 

 is a 

non-practising  solicitor  and  is  the  Regulatory  Counsel  and  Disciplinary  Officer. 

 is an engineer by background and is in the Safety Executive role at Motorsport 

UK.  

2.  Motorsport UK is recognised by UK Statute as a body Authorised to Permit motor sport 

competitions in the jurisdiction of the Court (and elsewhere) and further is recognised 

as  the  National  Governing  Body  of  4+  wheel  motorsport  in  the  UK  by  Federation 

Internationale  de  l’Automobile,  (‘FIA’)  the  World  governing  body  of  4  +  wheel 

motorsport,  pursuant  to  the  Statutes  and  International  Sporting  Code  of  FIA. 

Motorsport UK is a Founder Member of FIA and is placed by its representatives and 

nominees  on  the  World  Motorsport  Council,  the  International  Tribunal,  the 

International Court of Appeal and across the several sporting Commissions of FIA. 

3.  This  Response  is  necessarily  affected  by  the  fact  that  HMC  has  not  concluded  the 

Inquest to which the Report is related. The last Hearing of the matter at which live 

and other evidence was received, was 16 December 2022 and which was adjourned 

for further evidence which has been provided. HMC has additionally demanded other 

material,  to which it is argued  she  is  not entitled  as  it  concerns  unrelated  matters. 

Those  requests  are  the  subject  of  legal  correspondence  in  which  HMC’s  latest 

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 response  was  received  on  21  November  2023  and  which  invites  a  response  by  4 

December  2023.    The  Inquest  is  listed  to  resume  at  a  concluding  hearing  on  11 

December 2023. References below to Evidence received are to that variously given at 

the Hearing 16 December 2022 (‘the first hearing’) and thereafter to date. 

4.  Regrettably, HMC appears to have misunderstood the Evidence. 

5.  All  circuits  Licenced  for  Regulated  motor  sport  by  the  Statutorily  recognised 

authorised  bodies -  Motorsport  UK  and  the  AutoCycle  Union  (“ACU”)  in  this  case - 

rigorously  apply  the  application  of  and  requirement  for  appropriate  barriers  to  be 

positioned at relevant locations and the types of which depend on the various track 

features (simply expressed as straights or corners). 

6.  The Evidence provided to HMC at the first hearing included that of an acknowledged 

and  internationally  recognised  Expert  Track  Inspector  certified  in  the  approval  of 

circuits, including barriers, in the territories of FIA (including this jurisdiction) (

). His evidence is that the barriers in place in this instance were appropriate. 

Moreover, 

’ evidence is that the tyre barrier referred to did absorb energy, 

which in turn was evidenced by the movement of it. It is a matter of physics.  

7.  The global standards applied to course design and regulated inspection have rejected 

the use of Recticel (or similar other brands such as Airfence referred to by HMC) on 

straights because of the risks of pocketing associated with it. It is however deployed 

in relevant circumstances i.e. at corners where there is a ‘head-on’ risk. 

8.  The risk of pocketing has been referred to and acknowledged by HMC in the Report 

but, without any scientific premise, she has apparently rejected the views of experts. 

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 9.  Barriers cannot absorb all energy applied to them.  As offered in evidence at the first 

hearing and as recognised by HMC, barriers are intended primarily to keep competing 

vehicles within the course and thereby avoiding risk to persons outside the course. 

10. Thus the underlying premise of paragraph 5.1 of HMC’s Concerns cannot be accepted.  

There is no scientific basis or reference for the observations made.  It fails to take into 

account the expert evidence which the Court received on the issue at the first hearing.  

It  will  be  noted  that  despite  extensive  enquiry  by  local  authority  officers  at  the 

instruction of HMC, no other expert evidence was commissioned or called at the first 

hearing. 

11. Regarding  HMC’s  observations  at  paragraph  5.2  of  the  Report,  we  note  HMC’s 

comments regarding features between the track and barriers, in particular in this case 

wet grass.  We unavoidably but respectfully comment that HMC’s averment that ‘.. wet 

grass caused his kart to accelerate and collide …’ is simply, and scientifically wrong.  The 

fact of the grass being wet could not cause the kart to accelerate without additional 

force being applied to the kart.  Its retardation qualities may be reduced compared, 

for  example,  to  dry  grass  or  some  other  surface,  but  it  cannot  cause  objects  to 

accelerate. 

12. HMC’s comments regarding risk assessment in wet weather is noted, however that is 

already undertaken by highly trained and licenced officials at each Event as stated in 

Evidence at the First Hearing.  As those assessments are already a mandatory part of 

Regulated motorsport, no further action is required.  

13. Of  concern  however  is  the  premise  of  the  comment  at  paragraph  5.2  because  it 

suggests  at  one  possible  level  that  whenever  grass  is  wet  competition  should  be 

abandoned.  However, grass may be ‘wet’ for any number of reasons, even in otherwise 

dry weather depending on the time of year, including when freshly cut or dewed.  At 

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 another level HMC appears to opine that no competitive sport should occur whenever 

it is wet.  That appears to be unrealistic in the latitudes of the UK. 

14. Accordingly, in managing the obvious risks voluntarily accepted by written indemnity 

by  all  participants  (such  as  and  including  Mr  Wrigley)  under  the  contractual 

Regulations  of  the  sport,  this ASN  as  with  the  other  relevant  Statutory  authorities, 

requires  the  deployment  of  appropriate  and  suitably  installed  barriers  at  relevant 

locations on all Licenced courses and which is manifested by the recognised Statutory 

bodies granting Track Licences pursuant to the dynamic review of them by qualified 

experts. 

15. Where relevant to the nature and type of the competition, the course will also benefit 

from inspection and if satisfied the grant of a Track Licence by the FIA (for cars) and/or 

the FIM (for motorcycles and sidecars).  Note, Darley Moor is not a venue which has 

ever been used for FIA or FIM Permitted events. 

16. All  tracks  and  courses  are  inspected  by  vastly  experienced  qualified  engineers 

variously  employed  by  the  Statutory  authorities  or  the  FIA/FIM  where  applicable. 

Those inspectors are fully conversant with the relevant laws of physics and the nature 

of  the  relevant  competition vehicles  and  the nature  of  competition and  associated 

risks. 

17. All risk cannot be removed and participants freely acknowledge that. 

18. This  ASN  as  a  Statutory  authority  has  historically,  and  continues  currently  to 

collaborate nationally with other National Governing Bodies, and with the HSE on all 

such  matters.    Our  contribution  informs  both  the  HSE’s  knowledge  and  published 

guidance including HSG112 and the deployment of suitably installed and appropriate 

barriers as stated above, and is part of a working group in relation to such matters. 

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 REGULATORY COUNSEL 

MOTORSPORT UK 

23 November 2023. 

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