Prevention of Future Deaths reports · 2025

Richard Ellis

Regulation 28 report to prevent future deaths, reference 2025-0483, written 26 Sep 2025. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report26 Sep 2025
Reference2025-0483
DeceasedRichard Ellis
CoronerJoanne Andrews
Coroner areaWest Sussex, Brighton and Hove
CategoryRoad (Highways Safety) 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 DEATHS

THIS REPORT IS BEING SENT TO:

The Department for Transport,  Great Minster House 33 Horseferry Road London
SW1P 4DR

1

CORONER

I am Joanne ANDREWS, Area Coroner for the coroner area of West Sussex, Brighton
and Hove

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

I opened an investigation on 31 October 2023 into the death of Richard Ellis which
concluded by the inquest. The findings in relation to section 5 of the Coroners and
Justice Act 2009 were:

Richard Ellis died on 23 October 2023 at Harwoods Green Lane, Stopham, West
Sussex from injuries he sustained when a tractor struck him. The tractor was being
used to tow the deceased’s stranded vehicle up an incline. Having freed the
deceased’s vehicle, whilst still on the incline facing downhill, the tractor stopped
towing and was held on its handbrake. At that time the tractor’s handbrake failed
allowing the tractor to roll forwards into the deceased who was removing the tow
strap attaching his vehicle to the tractor.

4

CIRCUMSTANCES OF THE DEATH

The deceased was contracted to collect an electricity generator from a property
which was accessed via a track on a country Estate (“Estate”).

The deceased was using an Isuzu pick up (“Isuzu”) and trailer to do so. He collected
the generator from the property but due to the narrow nature of the track, he was
unable to turn his vehicle around to drive out forwards. Therefore, he reversed down
the track with the trailer. During this manoeuvre he became stuck on an incline
facing upwards as the wheels of the Isuzu and trailer had become stuck in a ditch
which ran alongside the track.

Regulation 28 – After Inquest

Template Updated 15/07/2025 TG

 The deceased therefore sought assistance from local Estate workers as he needed to
be towed out.

The Estate workers went to the location where the deceased had become stuck with
a 1996 Valmet 8130 tractor (“Tractor”) which was owned by the landowner. The
Estate workers placed the Tractor facing downhill pointing towards the front of the
deceased's Isuzu which was facing up the incline. The trailer was detached at that
time.

A strap was attached between the front of the Isuzu and the front of the Tractor. The
Tractor reversed and pulled the Isuzu from the ditch. The Isuzu became free whilst
still on the incline. The deceased and Tractor driver both got out of their vehicles and
detached the towing strap. The Tractor driver had placed the handbrake on the
Tractor prior to leaving the cab.

The Tractor handbrake then failed and allowed the Tractor to roll down the incline
onto its driver and the deceased. The deceased sadly died at the scene from his
injuries.

The handbrake was examined after the incident which demonstrated that the pawl of
the handbrake was significantly worn and would likely have slipped previously. The
evidence of the Tractor driver was that he had no concerns about the operation of
the handbrake prior to this event.

The Tractor had last been serviced in 2021 but the evidence that I heard was that it
was not a legal requirement for there to be any prescribed maintenance or servicing
of tractors solely used for agricultural, horticultural or forestry.

5

CORONER’S CONCERNS

During the course of the investigation my inquiries 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:
(brief summary of matters of concern)

The evidence was that there are no legal requirements for the servicing and
maintenance of agricultural tractors which do not fall within the requirements of the
Road Traffic Act 1988 and the associated regulations. As such, the maintenance of
these vehicles is dependent on the discretion of the vehicle owners.

6

ACTION SHOULD BE TAKEN

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

Regulation 28 – After Inquest

Template Updated 15/07/2025 TG

 7

YOUR RESPONSE

You are under a duty to respond to this report within 56 days of the date of this
report,
namely by November 22, 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

The family of Mr Ellis
The driver of the Tractor at the time of the collision
The owner of the Tractor
Southern Electric Power Distribution Plc
Plateline Limited

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 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. They may send a copy of this report to any person who they believe 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 by the Chief Coroner.

9

Dated: 26/09/2025

Joanne ANDREWS
Area Coroner for
West Sussex, Brighton and Hove

Regulation 28 – After Inquest

Template Updated 15/07/2025 TG

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 Department of Transport (PDF)
From the Parliamentary  
Under Secretary of State 

Great Minster House 
33 Horseferry Road 
London 
SW1P 4DR 

Web site: www.gov.uk/dft 

Joanne Andrews 
Area Coroner for the coroner area of West Sussex, 
Brighton and Hove, 
Chart Way, 
Horsham, 
West Sussex, 
RH12 1XH 

 31 October 2025 

Dear Ms Andrews, 

Thank  you  for  your  letter  of  26  September  2025  enclosing  a  Regulation  28 
Report  to  Prevent  Future  Deaths,  following  the  inquest  into  the  death  of  Mr 
Richard Ellis. I am deeply saddened to hear of Mr Ellis’s death and offer my 
sincere condolences to his family and friends.  

The Government treats road safety seriously and is committed to reducing the 
numbers of those killed and injured on our roads. The Road Safety Strategy is 
under development and will include a broad range of policies. More details will 
be set out in due course. 

While this incident has been classified as a road traffic collision, we understood 
it  took  place  on  a  public  bridlepath  on  a  private  estate.  Given  that,  as  I 
understand, my officials are not in possession of all the facts of the case, I have 
sought  to  provide  you  with  a  comprehensive  response  about  the  existing 
regulatory  frameworks  that  might  apply,  hoping  that  relevant  authorities  can 
take this forward.  

Relevant agricultural vehicle regulations for public roads 

Once a tractor enters service on a public road, its continued roadworthiness is 
governed  by  a  legal  requirement  that  all  vehicles  used  on  the  road  are 
maintained in a roadworthy condition at all times as set out in the Road Traffic 
Act  1988  and  the  Road  Vehicles  (Construction  and  Use)  Regulations  1986. 
These  regulations  cover  aspects  such  as  braking  systems,  steering,  tyres, 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
 visibility,  and  overall  vehicle  condition,  helping  to  ensure  that  agricultural 
tractors remain safe and compliant throughout their operational life. 

in  2016  on 

My  Department  conducted  a  consultation 
introducing 
roadworthiness  testing  for  fast  tractors  used  for  commercial  haulage. As  a 
result,  agricultural  tractors  capable  of  a  speed  over  40km/h  (approximately 
25mph)  being  used  for  commercial  haulage  were  brought  into  scope  of 
roadworthiness  testing  under  the  Goods  Vehicles  (Plating  and  Testing) 
Regulations 1988. At the time, it was decided that it would not be proportionate 
to bring slower speed agricultural tractors in scope of annual roadworthiness 
testing given their use on roads is limited in comparison with other vehicles.  

As  part  of  ensuring  compliance,  the  Driver  and  Vehicle  Standards  Agency 
(“DVSA”) conducts roadside checks throughout the road network.  Where non-
compliance  is  evident,  this  can  result  in  a  vehicle  being  prohibited  until  the 
weight is reduced or the defect rectified. In addition to prohibitions, DVSA also 
impose fixed penalties on the drivers of such vehicles which range from £50 to 
£300 depending on the severity of the offence. Alternatively, more severe cases 
may lead to criminal prosecution. 

The  DVSA  publishes  guidance  on  maintaining  roadworthiness  and  this  is 
available at the links provided below: 

https://www.gov.uk/government/publications/guide-to-maintaining-
roadworthiness/guide-to-maintaining-roadworthiness-commercial-goods-and-
passenger-carrying-vehicles 

This  guidance  covers  what  drivers  and  operators  are  legally  required  to  do 
according  to  the  law  and  highlights  the  fact  that  it  is  an  offence  to  use  an 
unroadworthy  vehicle  on  the  road.  This  guidance  also  gives  best  practice 
advice on the responsibilities that an operator or driver will have to consider to 
ensure the roadworthiness of their vehicle. This can also be used to support 
the maintenance of tractors solely used on private property. 

In addition, DVSA publish the Categorisation of Defects manual which is made 
available  so  that  vehicle  owners,  operators  and  drivers  can  become  more 
aware of DVSA’s standards and what will be done should problems be found. 
Part 1 of the manual is intended for heavy goods and public service vehicles 
and  may  also  be  used  for  agricultural  motor  vehicles,  trailers  and  trailed 
appliances: 

 
 
 
 
  
  
  
  
  
  
 https://assets.publishing.service.gov.uk/media/6748955424108edc3c8cebde/
categorisation-of-vehicle-defects.pdf 

Relevant agricultural vehicle regulations for private land 

If tractors are operated solely on private land with no public access, they are 
not  in  scope  of  road  vehicle  regulations  that  apply  on  public  roads.  This 
includes roadworthiness regulations under the C&U regulations that create the 
legal  requirement  to  ensure  the  roadworthiness  of  vehicles  on  public  roads, 
although as noted above the good practice guidance published by DVSA is still 
relevant. 

If the incident took place on a private land, there is health and safety legislation 
(Health  and  Safety  at  Work  Act  1974)  that  covers  the  maintenance  and 
servicing of agricultural vehicles. This legislation is enforced by the Health & 
Safety Executive and an employer is required to ensure, so far is reasonably 
practicable, the health, safety and welfare of both their employees and non-
employees who may be affected by their undertaking. The Provision and Use 
of Work Equipment Regulations 1998 (“PUWER”) provide a set of more specific 
duties in relation to work equipment, including that employers ensure their work 
equipment is maintained in an efficient state, in efficient working order and in 
good  repair.  This  is  also  maintained  by  the  HSE  and  we  suggest  that  you 
consider writing to them should the circumstances of this case fall under this 
legislation. 

The  HSE  provides  guidance  for  safe  workplace  transport  in  the  agricultural 
sector which can be found at the link below: 
https://www.hse.gov.uk/agriculture/topics/machinery/farm-vehicles-1.htm 

Departmental response 

In total, there were 353,269 tractors licensed on roads in Great Britain (“GB”) 
in 2024. Road collision statistics show that, over the last ten years, the number 
of  incidents  involving  an  agricultural  vehicle  where  someone  was  killed  has 
remained  relatively  stable.  Data  on  road  injury  collisions  held  by  the 
Department shows that in the ten years from 2015 to 2024 there averaged 21 
deaths  per  year  on  public  roads  in  GB  involving  agricultural  vehicles.  The 
Department  does  not  collect  data  on  accidents  that  take  place  on  private 
property. 

 
 
 
 
  
  
  
  
  
  
  
 In view of your report, I have asked my officials to investigate how best to raise 
awareness of the DVSA’s published guidance on maintaining roadworthiness 
and  to  consider  whether  additional  specific  guidance  on  agricultural  vehicle 
maintenance  should  be  published.    My  officials  will  consider  how  best  this 
information  can  be  communicated  to  operators  of  agricultural  vehicles, 
including those who operate tractors solely on private land.   

The  Department  will  continue  to  monitor  the  effectiveness  of  vehicle  safety 
regulations to identify any potential amendments. 

Once again I would like to express my condolences to the friends and family of 
Mr Ellis. 

Yours sincerely, 

MINISTER FOR LOCAL TRANSPORT

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