A coroner may not withhold relevant material from a witness at risk of an adverse s 19 finding for 'tactical' or forensic advantage reasons; withholding is only justified where it genuinely protects the integrity of the investigation. Where a witness has been warned of the possibility of a s 19 opinion and granted leave to appear, procedural fairness may require disclosure of all relevant material before the coroner has actually formed the s 19 opinion. The majority and dissent disagreed on the precise timing of the disclosure obligation, with the majority requiring earlier disclosure than the dissent.
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