January 1, 2025

The Inquest Hearing

Chief Coroner Coroners' Court Bench Book

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Introduction

1. By virtue of s.6 (external link) of the Coroners and Justice Act 2009 (the Act), once an investigation has commenced it must culminate in an inquest unless the investigation has been discontinued in accordance with s.4 of the Act (external link) or is suspended and not later resumed under schedule 1 (external link) of the Act.

Accessibility and location of inquests

2. A coroner must hold all inquest hearings in public unless the limited circumstances under the Coroners (Inquest) Rules 2013 at r.11(4) or r.11(5) (external link) arise. This means not merely open to the public but arranged in such a way that it is possible for a member of the public to attend in person.[1] The coroner must be in the publicly accessible courtroom and, in accordance with the principle of open justice, members of the public and press do not need to provide any reason for wishing to attend a court hearing.

3. Whilst the expectation will be that an inquest is normally held within the area of the coroner who is conducting the investigation, the Act allows inquests to be held anywhere in England and Wales, so there is flexibility as to the location of any inquest or pre-inquest review (PIR) hearing. Therefore, where the nature of an inquest requires a particular type of accommodation that is not available within the coroner’s own area the inquest can be held in another place outside the coroner’s area. This will commonly arise when there is a lack of available and appropriate court space for a jury inquest with multiple interested persons (IPs), or where it may be in the best interests of bereaved relatives to hold the inquest at a different location. Often this will be an adjoining jurisdiction, although at times (most commonly judge-led inquests) holding an inquest in a central venue in a major city may be appropriate.

4. Where a coroner has been appointed to sit in two areas, there may be occasions when it is expedient for the coroner to hold PIR hearings or to hear inquests in cases from those different areas from a single courtroom on the same day. Provided there has been adequate public notification given of the venue of the hearing this may be a proportionate use of coronial and court time.

5. When considering whether to sit outside the coronial area the coroner should take due account of the views of IPs, in particular the bereaved, and the distance participants may have to travel to attend a hearing in person.

Age limits on attending Court

6. Whether attending remotely or in person there is no statutory age limit on who may attend a coroner’s court as a member of the public. Under s.36 Children and Young Person’s Act 1933 (external link) no child (other than an infant in arms) may attend a criminal trial except where their presence is required as a witness, or for the purposes of justice, or with the court’s consent. However, in the absence of any equivalent provision in coronial law it is suggested that permitting a child to attend a coroner’s court falls within the coroner’s common law power to control their own proceedings.

7. The matter should be considered by weighing up the relevant issues including the administration of justice, the interests of open justice and, if relevant and ascertainable, the wishes of the child (having regard to their age and understanding) and whether attendance would be in the child’s best interests.

8. Facilitating school age students to observe court proceedings can aid diversity in the legal profession. Having a blanket ban on the attendance at court of children of a particular age as public observers is likely to be unlawful. Each case must be considered on its merits. It would be reasonable to have (and publish on the coroner’s website) a policy that children of a specified age can attend court without needing to request specific permission, but that children under a specified age (for example 14 years) should seek the coroner’s consent on an individual basis.

An inquest script

9. Most inquests held by coroners are brief and uncomplicated hearings and can follow the format below. Whilst coroners may of course use their own words adapted for the particular case, it is important that the record is clear and complete for every inquest. Therefore, if several brief hearings are being held on the same day a formal introduction to each hearing is advised.

10. It is important to remember that those IPs who attend without the assistance of lawyers should always have the basic court procedure and legal principles explained to them by the coroner so that they can better understand the process in which they are participating. Giving an early explanation of the ‘level of confidence’ that must be applied in inquests will assist all participants to understand the basis upon which any factual findings and conclusions will, eventually, be made.

11. When issues of law are likely to arise at the end of the hearing, it may be helpful for the coroner to give a brief outline and explanation of those legal considerations in advance of the evidence being heard. For example if a likely issue at the end of an inquest will be whether a killing was unlawful then a basic outline of the law of gross negligence manslaughter or self-defence (if relevant) might be given. Such explanations, even provisional ones, can help unrepresented IPs to feel that their presence matters and that they are being kept informed and consulted throughout the inquest process.

12. The outline below may be a helpful script to follow in a simple inquest:

At the outset of the hearing

introduce yourself and note the date;
give any permission required for remote attendees to observe the proceedings;
state the name of the deceased and their date of death (if not in issue);
confirm (if this is the case) that this is a resumed inquest and give the date of the opening;
identify the IPs, starting with the bereaved;
if legal representatives are present, ask them to introduce themselves and say who they represent and who is attending court with them;
if appropriate, introduce others present in the courtroom;
inquire of the bereaved what name they prefer to be used when referring to the deceased;
advise that the purpose of the inquest is to identify the medical cause of death, and to answer four statutory questions: who died, when and where they died, and how they came by their death.
advise that the court must also come to a conclusion about their death, (coroners may wish to explain that this used to be called a ‘verdict’ although that word is no longer used).
advise that an inquest is not a trial, that no person or organisation is on trial and it is not the coroner’s role to attribute blame;
explain the level of confidence that the coroner/jury will apply to findings of fact and conclusions;
explain the intended scope of the investigation and inquest;
explain any legal considerations that it is anticipated will need to be addressed at the end of the evidence;
state that in order to address those matters within the scope of the investigation ‘the following evidence will be called’ then cite the witness list indicating whether a witness will attend in person or their evidence will be read;
explain that you shall be asking questions of all the live witnesses first and then offer the bereaved and other IPs the opportunity to ask questions of the witnesses, with the witnesses’ own legal adviser going last (if they have one);
explain the effect of r.23 and under which sub-section the evidence to be read is admitted. Make it clear that the evidence is either not disputed or where not accepted by all, explain why the witness’ attendance is not required.
confirm with the IPs present that no one objects to the evidence being read.[2]
check that all IPs have received the advance disclosure and there are no preliminary housekeeping matters.
Note that evidence of identity was given at opening and by whom.
Call any pen portrait material that is to be presented.[3]
Call the first factual witness or read the first documentary evidence.

At the end of the evidence

indicate that this is all the evidence you had intended to hear regarding the death.
ask if any IP suggests there is any other evidence that should be considered.
ask if any IP wishes to make any submission of law regarding the available conclusions.
deliver a brief ruling on available conclusions if required.
explain that as the evidence is now concluded you will retire for a short while to consider the evidence and your conclusions.

Findings and conclusions

state that the following are the findings and conclusions for the purposes of the inquest.
summarise the relevant evidence. Explain how the court interprets the medical evidence, and any other expert evidence, in simple language.
make findings of fact based upon the evidence, stating ‘why’ or ‘because’ where appropriate.
indicate what medical cause of death is found to be from the evidence as 1a etc…………. and this is what shall be recorded on the Record of Inquest.
state what shall be recorded in box 3 of the Record of Inquest as the time, date, place and circumstances of the death.
give the conclusion as to the death and that it shall recorded as this in box 4 of the Record of Inquest.
where appropriate, give the details required for the registrar as in box 5.
if necessary, announce that a report with a view to preventing future deaths will be written.
announce that this concludes the inquest, thank those attending and express necessary condolences.

13. There is no longer a statutory requirement for coroners to take and keep their own notes of evidence at an inquest.^[4] Coroners’ own notes are no longer disclosable and cannot be inspected. However, as good practice coroners will still keep their own notes for their rulings, conclusions and summing up.

Pen portraits

14. The practice has developed of permitting material to be adduced before the coroner (and the jury where relevant) concerning the life of the person at the heart of the inquest. This has become known as a ‘pen portrait’. Not all those bereaved will wish to do this, but it is appropriate for the opportunity to be offered when the bereaved will be attending an inquest. Exceptionally, cases may also arise in which it would not be appropriate to allow the use of pen portraits (for example, where the deceased committed an unlawful killing and a pen portrait would cause the victim’s family unjustifiable distress).

15. Pen portraits do not usually arise in documentary inquests because there is often just the coroner in the courtroom and no family members are present, although a written pen portrait can be considered at documentary inquest, even if the bereaved do not wish to attend.

16. In other relatively short but attended inquests where the bereaved are present, the coroner will generally ask them to let the court know something of their loved one in life – what he or she did, their interests and hobbies and details of their wider circle of family and friends.

17. The coroner should inform the bereaved well before the inquest hearing that they will be invited to present such material should they wish to do so. In more complex cases or jury inquests the directions given at a Pre-Inquest Review should cater for the presentation of pen portraits.

18. In many cases, a family member will wish to read out their own tribute, at other times the bereaved may find this difficult and prefer a lawyer, the coroner or a coroner’s officer to do this for them. Families may wish to include some photographs or imagery from the life of the deceased. The type of material to be permitted, the amount of it and the timing of its admission will be a matter of judgment for the coroner.

19. It is not obligatory for pen portrait material to be presented under oath, as it often does not form part of the inquest evidence, but if the bereaved person is also giving registration particulars or other factual evidence it may be necessary for them to take an oath at the outset.

20. The coroner should make it clear to any jury that the pen portrait is to be a reflection of who the person was in life rather than any information about how the death occurred. It is not a matter of evidence to be taken into account when deciding on the conclusion. Depending on what is said the coroner may have to warn the jury that what was presented is not evidence.

21. Even where there have been multiple deaths arising from the same incident it should be considered extremely unusual to introduce pen portrait material for a person who is not the subject of the inquest proceedings. An alternative course is for the coroner to acknowledge at the outset of the proceedings that others also died, although their deaths are not being inquired into in the current inquests,[5] and perhaps also name the other deceased if appropriate.

The content of pen portraits

22. An advance copy of any pen portrait should usually be given to the coroner and all other IPs. It will be incumbent on the coroner conducting the inquest to scrutinise the pen portrait material and decide what is permissible and when the material is to be adduced. On occasions it may be appropriate for the coroner to refer to the pen-portrait material again or quote directly from it at the end of the inquest when closing the proceedings.

23. Coroners should always carefully review whether the material put forward by the bereaved goes beyond what is appropriate to include within a pen portrait. The pen portrait process should not stray from its intended purpose and be used, whether intentionally or unintentionally, to make pejorative observations on the actions of others or to pass comment on the evidence yet to be heard. A pen portrait should not be used as a means of making inadmissible commentary within the courtroom on the matters the coroner is investigating. It should not include material that undermines the rule 27 (external link) prohibition on addressing the facts. Those delivering pen portraits should not be allowed to make speeches addressing their view of how the death occurred which seek to persuade the coroner or the jury what facts to find or which conclusion to return.

24. As pen portraits are read out in court they become an integral part of a judicial coronial process. That pen portraits are usually not delivered under oath should make no difference to the need for them not to stray beyond their intended focus as a tribute to the deceased and the person they were in life.

Photographs displayed in court

25. The family may bring photographs of the deceased to court that they wish the coroner (and, where there is one, the jury) to see. It is appropriate for such images to be shown as requested, they are an important recognition of the person to whom the inquest relates. However on occasion a bereaved person may ask that an image of the deceased remains on display in the courtroom during the inquest. The coroner will need to determine whether to permit such display throughout the hearing. It may not be appropriate to do so if such imagery might distract the jury or might affect the witnesses and so impact upon their ability to give their best evidence. One approach is to place the photograph where it remains visible to the coroner, but not to others.

Language in court and equal treatment

26. The Equal Treatment Bench Book (‘ETBB’) provides important guidance for all judges and coroners and it should be taken into account where applicable in coronial proceedings. The ETTB aims to increase awareness and understanding of different people’s circumstances, and it makes suggestions regarding steps coroners may wish to take, in different situations, to ensure that there is fairness for all those who engage in proceedings in coroners’ courts.

27. The ETBB is regularly updated and so care should be taken not to over-rely upon printed and therefore potentially out of date copies. Its contents are not repeated here beyond some salient points about the use of language in court.

28. There are expressions and terms which should not be used at inquests as they may cause offence. In particular, coroners will want to avoid the following:

saying ‘committed suicide’ as this suggests a criminal act. The words ‘died by suicide’ are more acceptable
referring to a ‘successful suicide attempt’: this may distress the bereaved. Similarly where someone has survived an earlier suicide attempt, coroners should avoid describing this as ‘unsuccessful’ or ‘failed’
talking about people as if they are medical conditions: for example avoid saying ‘a dyslexic’ or ‘a diabetic’ – use instead ‘a person with dyslexia/diabetes’
using negative terms such as ‘suffers from’ – use instead ‘has’, ‘experiences’ or other more neutral terminology
comparisons with ‘normal’ and referring to ‘the disabled’ as if they were a distinct class
referring to someone as ‘handicapped’ – use instead ‘disabled person’. Similarly avoid the term ‘mental handicap’ – use instead ‘learning disability or disabilities’ or ‘learning difficulties’
referring to someone as being an ‘addict’, ‘drug abuser’, ‘clean’ – use instead ‘has a substance misuse disorder’, ‘has an addiction’, ‘is abstinent from drugs/in recovery’
using the term ‘mental illness’ except when discussing a diagnosed clinical condition, otherwise use instead ‘mental health issues’ or ‘mental ill health’
Using the term ‘mental capacity’ incorrectly; it is a very specific phrase which as a technical legal meaning under the Mental Capacity Act 2009.

Signing the Record of Inquest

29. The Record of Inquest must be signed by the coroner (and, if there is a jury, those members of the jury who agree with it). Most coroner areas now use software systems whereby forms are signed electronically by the coroner and ‘wet ink’ signatures are becoming rare.

30. Coroners are reminded that any use of pre-signed forms should be avoided. The signing of a blank or incomplete form by a coroner is a misuse of the coroner’s judicial functions. The signature is an acknowledgment that the form is complete and accurate for its legal purposes, which it is not if left to be completed by someone else. If somebody else, such as a coroner’s officer, then completes the details on the signed form, that becomes a purported judicial act which is not permitted. Only coroners can carry out judicial functions. Such practices are unlawful and could put the coroner at risk of an investigation by the Judicial Conduct Investigations Office.

Translators and interpreters

31. Witnesses at inquests who are not sufficiently proficient to give evidence in the language being used in the court must have the assistance of an interpreter, preferably a professional one. In inquests held in Wales, the Welsh language may be spoken by any person, not just a witness.[6] A coroner sitting in Wales will need to establish at the PIR whether any persons intend to exercise their right to speak in Welsh at the inquest. A person who is bilingual in Welsh and English should not be required to speak in English if they do not wish to do so. It will also be prudent to ensure at an early stage that an interpreter will be present to translate from Welsh to English for the benefit of any persons present who are not bilingual.

32. A witness who has a hearing or speech impediment may also need special assistance from an interpreter, although in some cases assistance may be given by an intermediary.

33. IPs may be witnesses, in which case they are entitled to give evidence through an interpreter. Where they are not witnesses, they may be entitled to interpreter assistance provided by the court, as it is necessary in the interests of justice that IPs should be able to participate sufficiently in the investigation and inquest process. Coroners have a positive duty to ensure that sufficient participation is achieved, indeed this is one of the requirements of an Article 2 inquest.

34. It may be tempting to continue without an interpreter if a bereaved family member or witness says they can manage in the language being used in the court, however a coroner should exercise caution about accepting such reassurances. It is preferable only to accept the assistance of a family or friend where the person they are assisting does have a grounding in English/Welsh and simply needs assistance with a few words, phrases or constructs.

35. Guidance on the use of a translator or interpreter has been set out in the Equal Treatment Bench Book.[7] Ultimately, it is the coroner’s responsibility to ensure that there is a fair hearing.

36. It is a matter for the discretion of the coroner how to achieve fairness in the particular case. Where someone has limited ability in the language being used in the court then a professional interpreter is likely to be required.

37. Once satisfied that translation and/or interpreting services are required, the coroner will decide which method in §36 below is most appropriate. This will depend upon the circumstances of the case, the extent to which the inquest is contentious, the nature of the documentation and the evidence (whether straightforward or involving complexity, difficulty, or experts). A coroner who fails to provide such services when they are truly necessary for the bereaved or another IP to participate in the proceedings is likely to be vulnerable to challenge by way of judicial review.

38. Assistance in translating or interpreting may be achieved in several ways:

where the coroner requires professional translation or interpreting services, this should be funded by the local authority. Often the local police may be able to assist to identify a locally based translator
in non-contentious cases a friend or relative of the person may help if the person is not fully fluent in English and just needs assistance with a few words or phrases, but a friend or relative should not be relied upon where extensive translation is required
assistance may be obtained on a voluntary basis from a local foreign nation association or relevant charity, however the coroner will need to be satisfied that the translations will be (a) accurate and (b) strictly confined to translation with no extraneous comment or gloss
an IP may be represented and have either private or public funding or be able to obtain funding for translation and interpreting
there are some helpful free translation services available on the internet where it is only a matter of clarifying specific words or technical terms;
it will rarely be appropriate to use anything other than a professional interpreter in cases that are likely to be contentious.[8]

39. Sometimes it may be necessary to remind an interpreter to say the words of the question and the words of the answer and nothing more. Coroners must be satisfied, as best they can, that the interpreter is carrying out the task strictly and with true independence. All interpreters, including family members assisting without any charge, should be asked to take an oath or affirmation.

The interpreter’s oath
I swear by Allah/Almighty God, etc., that I will well and faithfully interpret and true explanation make of all such matters and things as shall be required of me according to the best of my skill and understanding.

The interpreter’s affirmation

I do solemnly declare that I will well and faithfully interpret and true explanation make of all such matters and things as shall be required of me according to the best of my skill and understanding.

Inquest recordings

40. All inquest hearings must be recorded.[9] This includes pre-inquest review hearings and, where practicable, openings.[10]

41. A recording (which is a ‘document’ for the purposes of the rules and regulations) must be kept for at least 15 years.[11] All recordings should be digital and stored with appropriate back-up or held in a secure cloud-based system.

42. Coroners’ officers or administrative staff should be able to set-up the recording device for each hearing. The coroner should take reasonable steps to ensure that the device is working at all times. At each inquest hearing coroners should consider informing those present that the hearing is being recorded and advise them to be careful about asides or comments which might be picked up by the court microphones.

43. It is a contempt of court for any person to use in court or bring into court for use any instrument for recording sound, except with the leave of the court.[12] However, there are now several artificial intelligence transcription applications available which can greatly assist those otherwise expected to take verbatim notes of a hearing. With this in mind, any application for leave from IPs, their legal representatives or members of the media might be treated sympathetically, subject to clear restrictions being placed upon the use of any recording made. If leave is granted, conditions may be attached.[13]

Copies of recordings

44. Coroners (either themselves or through a coroner’s officer) may wish to inform bereaved families that they can request a copy of the recording after the inquest.

45. In accordance with the disclosure provisions of Part 3 of the Coroners (Inquests) Rules 2013[14] a copy of a recording must be made available to an IP on request. The coroner may either provide a copy or make the recording available for ‘inspection’, subject to the restrictions on disclosure in rule 15 (external link). However, a recording need not be provided of any hearing or part of a hearing where the public was excluded.[15]

46. A copy of a recording may also be provided by the coroner ‘to any person who in the opinion of the coroner is a proper person to have possession of it’.[16]

47. In the latter case coroners have a discretion whether to provide a recording. They should exercise their discretion on a case by case basis; a policy to restrict groups of people would be unlawful (fettering the coroner’s discretion). The coroner needs to be satisfied that there are reasonable grounds for disclosure, however, the presumption of openness for court proceedings gives rise to a presumption of disclosure.[17]

Use of inquest recordings

48. It is an offence under s.9(1)(b) of the Contempt of Court Act 1981 (external link) to publish an inquest recording, or any recording derived directly or indirectly from it, by playing it in the hearing of the public or any section of the public.

49. Where a recording is provided to any person it should therefore be accompanied by a written notice advising that the misuse of the recording may amount to contempt of court punishable by imprisonment.^[18]

50. Whilst the recording of a court hearing cannot be broadcast without breaching the Contempt of Court Act 1981, the same rules do not apply to a transcript taken from a recording. There appears to be no general bar to transcripts being published, quoted from, re-voiced or re-enacted. Of course, anyone publishing these types of information must comply with any relevant prohibitions, for example there is a general prohibition against publishing the names of living victims of sexual offences, there may be reporting restrictions, an anonymity order, or an order made under s.39 Children and Young Persons Act 1933 (external link) in effect etc. A warning notice should be given to recipients of recordings to explain this.

51. In advance of receiving a copy of the recording the intended recipient should sign to acknowledge receipt and understanding of the warning notice. A suggested warning notice is below.

Inquest Recording: Warning Notice
It is an offence under s.9(1)(b) of the Contempt of Court Act 1981 to publish an inquest recording, or any recording derived directly or indirectly from it, by playing it in the hearing of the public or any section of the public.
You should not provide the inquest recording or a copy of the inquest recording to another person without the prior agreement of the coroner.
Use of an inquest recording or any part of it by copying, publishing, transmitting, or broadcasting the inquest recording in any way (including on the internet), may be a contempt of court punishable with imprisonment. However, you may listen to the inquest recording yourself and use it to produce a written transcript.
There is no general prohibition on using the information gained from a recording or transcript to quote, re-voice or re-enact an inquest, or part of an inquest.
However, if you are considering publishing information about an inquest, you should be aware that:
– there are specific provisions preventing the publication of some types of information; and
– it is possible for the publication of information to cause harm to others (see for example, the Samaritans’ media guidelines on reporting suicide).
If you are unfamiliar with the law around the publication of information, you may therefore wish to consider taking legal advice.
If you use the recording to produce a transcript, the transcript must not be presented as a court-approved transcript unless it has been seen and approved as such by the coroner. Only an approved transcript of an inquest recording should be used for the purpose of any further legal proceedings.
Signed (by the coroner)
Dated

Inquest transcripts

52. Unless the inquest is one where a contemporaneous transcript has been created during the proceedings,[19] it is not expected that a coroner will provide post-inquest transcripts at their own expense. Only a recording is required to be provided.

53. Where a recording is deployed by an interested or other person to produce a transcript of the inquest for the purpose of any further legal proceedings (such as a judicial review application), then that transcript should be provided to the coroner and checked to confirm its accuracy. Any warning notice sent out with a recording should therefore include that provision.

54. Where, exceptionally, the court produces the transcript, a fee may be charged for transcription in line with regulation 12(5) of the Coroners Allowances, Fees and Expenses Regulations 2013 (external link).[20]

[1] Storer v British Gas plc (external link) [2000] 1 WLR 1237

[2] This step is required in compliance with rule 23(2)(c) (external link). It is particularly important where the bereaved are not represented as they may not understand their right to object to evidence being read. If any objections are raised at this stage they must be considered and, if not acceded to then, as a minimum, brief oral reasons for the decision not to call the witness must be given.

[3] See §12 below.

[4] As there was previously under r.39 and r.57(1) of the Coroners Rules 1984.

[5] This might arise in cases of multiple deaths abroad, where the bodies of those who are the subjects of the inquest were returned to England or Wales.

[6] Welsh Language Act 1993 (external link), s22(1), therefore this includes IPs, their advocates and the coroner.

[7] For further guidance see the Equal Treatment Bench Book at chapter 8 – ‘How to communicate through an interpreter and translation difficulties’.

[8] For these purposes services for translation or interpreting may be treated as an ‘unusual allowance, fee or expense’ under Regulation 7 of the Coroners Allowances, Fees and Expenses Regulations 2013 (external link), or, for interpreting in court, as an ‘additional expense’ relating to a witness under Regulation 11 (external link).

[9] rule 26, Coroners (Inquests) Rules 2013 (external link).

[10] Coroners may wish to consider at the end of each hearing, with a view to possible future requests for a recording, whether a note (oral or written) should be made to indicate if redaction of the recording may be necessary, such as where there is a risk of prejudicing law enforcement action or the administration of justice, affecting national security, putting anyone’s safety at risk, identifying an anonymous witness, naming children, breaching medical confidentiality or breaching a contempt of court order.

[11] regulation 27(1), Coroners (Investigations) Regulations 2013 (external link).

[12] section 9(1), Contempt of Court Act 1981 (external link).

[13] section 9(2), Contempt of Court Act 1981 (external link).

[14] see in particular rule 13 (external link).

[15] rule 13(2)(c) (external link)

[16] regulation 27(2) (external link)

[17] A coroner may charge for providing a copy of a recording after an inquest (but not before) in accordance with the Coroners Allowances, Fees and Expenses Regulations 2013 (see regulation 12) (external link). The statutory fee for a ‘document’ provided otherwise than by email, and therefore including a recording on disk or memory stick, is £5 per recording: regulation 12(4). It is however preferable to offer recordings via a secure cloud based service, although no fee may be charged: regulation 12(2) (external link).

[18] See, by analogy, AG v Scarth [2013] EWHC 194 (external link) (Admin) (Lord Judge CJ), which involved the contemnor making and publishing on the internet his own audio recording of court proceedings.

[19] As is more often the case in high media profile judge-led inquests.

[20] At the time of publication for a copy consisting of 1,440 words or more, £13.10 for the first 1440 words and 70p for each additional 72 words or part thereof.