Prevention of Future Deaths reports · 2025

Michael Pugh

Regulation 28 report to prevent future deaths, reference 2025-0378, written 25 Jul 2025. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report25 Jul 2025
Reference2025-0378
DeceasedMichael Pugh
CoronerPatricia Harding
Coroner areaKent and Medway
CategoryState Custody related deaths · Suicide (from 2015)
Organisation namedOxleas NHS Foundation Trust
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

THIS REPORT IS BEING SENT TO:

1.
Service Executive Director Public Sector Prisons South

, His Majesty’s Prison and Probation

CORONER

I am Patricia Harding, senior coroner for the coroner area of Kent and Medway

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.

1

2

3

INVESTIGATION and INQUEST

On 3rd July 2024 I commenced an investigation into the death of Michael Pugh, 29
years. The investigation concluded at the end of the inquest on 21st July2025. The
conclusion of the inquest was suicide; Mr. Pugh having suspended himself in his cell at 
HMP Swaleside 

.

4

CIRCUMSTANCES OF THE DEATH

Michael Pugh was found in his cell on 29th June 2024 having died. He was subject of
an ACCT at the time of his death. It was determined at the last ACCT review before his
death that he should be subject to hourly observations. Observations were carried out
on the afternoon of 28th June 2024 but recorded incorrectly. No observations were
carried out on 29th June 2024 between 07.22 and 09.57 when Mr. Pugh was discovered
having died, but the ongoing record was completed retrospectively to show that they
had been carried out

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.  –

(1) The prison officers who gave evidence in relation to observations on 28th and 29th
June 2024 were relatively new recruits, one having 3 months experience following
POELT training and the other 1 month experience. Both officers gave evidence that
following their POELT training their understanding of the ACCT process was
incomplete; one stating “observations were explained but I didn’t have a fair idea what
to do or how to undergo the process”, another stating “I didn’t understand the
importance of observing a prisoner at unpredictable times. Even though I was told the
observations should be hourly it was not explained to me how to stagger timing. I
misunderstood what was required of me in recording the details when I recorded them
as having happened at 13.00, 14.00, 15.00 and 16.00.

 6

7

ACTION SHOULD BE TAKEN

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

YOUR RESPONSE

You are under a duty to respond to this report within 56 days of the date of this report,
namely by 19th September 2025. 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.

8

COPIES and PUBLICATION

I have sent a copy of my report to the Chief Coroner and to the following Interested
Persons Mr. Pugh’s next of kin, Ministry of Justice, Oxleas NHS Foundation Trust. I
have also sent it to Prison and Probation Ombudsman who may find it useful or of
interest.

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
useful or of interest.

The Chief Coroner may publish either or both in a complete or redacted or summary
form. 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.

 9

DATE  25TH July 2025                                   SIGNED BY CORONER Patricia Harding

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 Hm Prison Probation Service (PDF)
Director General of Operations  
HM Prison and Probation Service  
8th Floor Ministry of Justice  
102 Petty France  
London  
SW1H 9AJ  

Patricia Harding 
Senior Coroner for Kent and Medway 
Oakwood House 
Oakwood Park 
Maidstone 
Kent 
ME16 8AE 

12 September 2025 

Dear Ms Harding, 

Thank you for your Regulation 28 report of 25 July 2025 following the inquest into the death 
of Michael Pugh at HMP Swaleside on 29 June 2024. I am responding on behalf of His 
Majesty’s Prison and Probation Service (HMPPS) as the interim Director General of 
Operations.  

I know that you will share a copy of this response with Mr Pugh’s family, and I would firstly 
like to express my condolences for their loss. Every death in custody is a tragedy and the 
safety of those in our care is my absolute priority.  

You have expressed concern regarding the Assessment, Care in Custody and Teamwork 
(ACCT) training provided to new prison officers during their initial Prison Officer Entry Level 
Training (POELT). 

I would like to assure you that HMPPS are committed to providing prison officers with the 
right support, training and tools to empower them to do their jobs.  

All new members of staff receive a full day of training on suicide and self-harm prevention 
during their POELT training. This includes training on the ACCT process and the 
appropriate timings and intervals of when ACCT observations need to be carried out and 
recorded. Following completion of POELT training, new entry officers have a two week local 
induction before ‘going live’ and becoming fully operational. Part of this local induction 
programme at Swaleside includes ACCT upskilling and a session based on completion of 
ACCT documents and recording of ACCT observations. The local training team keep a 
record of these sessions. Any further training needs for staff would be identified and 
delivered locally.    

Additionally, any member of staff who undertakes a key role relating to ACCT case 
management, for example ACCT assessors or case co-ordinators, receives training specific 
to these roles. 

In addition to the training HMPPS has an online Safety Learning Reference Library which 
holds various guidance, templates and training material, all of which are accessible to all 
staff via the HMPPS intranet. The library includes an area dedicated to ACCT where staff 
can access a ‘Recording Observations’ video guide as well as a written guide, both of which 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 include examples of best practice for carrying out ACCT observations. Going forward HMP 
Swaleside will promote the Safety Learning Reference Library to new members of staff 
during their induction and, furthermore, will signpost the Safety Learning Reference Library 
to all staff during the HMPPS annual national safety focus initiative being held next month. 

I hope the measures outlined above provide you with reassurance that learning and 
appropriate action has been taken following Mr Pugh’s death.  

Yours sincerely 

   Director General Operations

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