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role for bereaved families and community groups to voice their concerns
and help provide a mandate for its work. 281
6.18 Dame Elish Angiolini endorsed the proposal, recommending the establishment
of an “Office for Article 2 Compliance”. 282 There is little material difference
between the proposals. Noting that reform of deaths in custody policy concerns
not only policing, “but also local government, the NHS and other health
providers, and other agencies”, Dame Elish stressed that “in order that the
findings of this review are properly taken forward, coordinated action taken
over a sustained period of time within a broad range of agencies is required. It
needs to be concentrated in one place with resources and organisational
memory” [emphasis added]. 283
6.19 Despite the substantial body of research marshalled in the Angiolini Review,
and the author’s finding that the preventative function of Article 2 ECHR
processes is “not yet being achieved adequately or consistently”, Government
dismissed the proposal in a single paragraph, finding that “a new and distinct
Office for Article 2 Compliance is [not] the most effective means of driving
compliance with Article 2 of the [ECHR]. Rather, it must be recognised that
existing agencies have a role to play here and their collation and dissemination
of learning in this area must be made more effective…coroners, inspectorates,
watchdogs (such as the IPCC) and the Ministerial Council on Deaths in
Custody should work towards strengthening their collaboration in this
regard…”. 284
6.20 The Working Party considers that encouraging greater collation and
dissemination of information (Chapter II), enhanced collaboration (Chapter
III) and the establishment of a discrete national oversight mechanism are not
mutually exclusive. Failure of public authorities to implement the findings of
281 Angiolini, supra note 15, para 17.26.
282 Ibid, para 17.22-36.
283 Ibid, para 17.36.
284 HM Government, ‘Government response to the Independent Review of Deaths and Serious Incidents
in Police Custody’, October 2017, para 2.108.
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