Manslaughter by Coercive Control: UK Law Reform 2026

Content note: This article discusses and describes sensitive topics. If you are currently experiencing abuse or are in early recovery from coercive control, please read with care, or seek support from Samaritans.

You didn’t know, did you? How could you guess what went on behind closed doors and behind smiling social media pictures? Who could have imagined you would find yourself at the inquest, staring at those same smiling photos next to the unthinkable headline? Now you know that what was happening to her was not just abuse. You know that the person breaking her down knew exactly what he was doing. And you know that she didn’t survive it. The term manslaughter by coercive control names what survivors and bereaved families already understand. A perpetrator’s sustained campaign of psychological domination can drive a person to her death. That death is not separate from his hand.

In the United Kingdom, families are pushing for the law to catch up with the evidence. Specifically, they are pushing for a statutory offence that names what perpetrators are doing when their victims take their own lives following coercive control. So far, the law has been slow. However, it has begun to move. This article maps where the campaign now stands, why it matters, and what survivors and families need to understand about the current state of the law.

What Manslaughter by Coercive Control Means

Manslaughter by coercive control names a legal principle¹. Specifically, a perpetrator who engages in sustained coercive and controlling behavior can bear criminal responsibility when the recipient of the abuse takes their own life. The principle does not require the perpetrator to have physically caused the death. Rather, it requires that their unlawful conduct caused the victim’s self-inflicted death. The conduct includes the offense of coercive and controlling behavior itself.

In England and Wales, manslaughter remains a common law offence. Therefore, no specific statutory offence of “manslaughter by coercive control” currently exists. Families and campaigners argue this gap is the central problem. The legal route is theoretically open. However, in practice, it stays closed. As a result, coercive control perpetrators walk free from criminal accountability for deaths their conduct caused.

Why a Specific Offence Matters

Currently, prosecutors must rely on the general law of unlawful act manslaughter. The prosecution must prove three things. First, the perpetrator’s unlawful act caused the death. Second, the act was dangerous. Third, the causal link is sufficient in law. In practice, this evidential threshold has proved extraordinarily difficult to meet. Consequently, prosecutors have charged precious few cases. Fewer still have ended in conviction.

A statutory offence would do three things. First, it would name the harm specifically. Second, it would guide police and prosecutors on what evidence to gather and how to frame the charge. Third, it would send a public signal. The law recognizes what perpetrators do when they drive their partners to die.

The Chloe Holland Campaign

Sharon Holland of Portsmouth launched the campaign for a statutory offense of manslaughter by coercive control.² Her 23-year-old daughter Chloe took her own life on 1 February 2023. Chloe had endured a year of sustained coercive and controlling behavior by her partner, Marc Masterton. She was a mother of one. She was, in her mother’s words, a ray of sunshine.

Prior to her death, Chloe reported her ex-partner to the police. The court subsequently sentenced him to 41 months in prison for the crime of coercive control. However, no legal route existed to hold him accountable for driving Chloe to her death.

Ms. Holland recalled the psychological oppression her daughter suffered:

“He controlled who she spoke to, what friends she had on Facebook, he controlled her phone, I would say he controlled her finances, he controlled her freedom — and he also controlled her seeing her son. Her appearance changed — she stopped wearing her fake eyelashes, her makeup, her hair was tied up, her clothes were more covered up — she just didn’t look herself.”

Sharon Holland

This is the texture of coercive control as practitioners encounter it. The perpetrator dismantles the person piece by piece. They shrinks the target’s social world. They decides what the recipient of the abuse wears, how they look, who they speaks to, what they eats, where they go. The visible markers of the target’s identity disappear into controlling person’s preferences. Then the abuse perpetrator isolates the target further. Eventually, the voice in her own head is no longer hers. To learn more about how this happens, read What Is Coercive Control. For a first-hand account, read The Use of Isolation In Coercive Control.

The Petition and Its Reception

In late 2023, Ms. Holland launched a parliamentary petition. The petition called on the government to create a specific statutory offence of manslaughter by coercive or controlling behaviour. Notably, the proposed legislation would apply where coercive or controlling behavior caused someone to take their own life.

By December 2023, the petition had reached more than 10,000 signatures. At this threshold, the government must issue a formal response. Speaking after the milestone, Ms. Holland said:

“This momentous support further emphasizes the critical need for legislative change to address the devastating impact of coercive control. Our collective efforts bring us closer to achieving justice for victims and holding perpetrators accountable.”

Sharon Holland

Her campaign drew support from Aurora New Dawn, a British domestic abuse charity. The charity submitted evidence to the Public Bill Committee on the Criminal Justice Bill. Their evidence underscored that Chloe’s death was not a unique phenomenon. Indeed, their direct experience working with victims across the UK confirms a pattern. Perpetrators of coercive control frequently tell victims they would be better off dead.

The Government Response

On January 18, 2024, the government issued its formal response to the petition.³ The response declined to create a specific offence. Instead, the government stated:

“The Government has no plans to create a specific offence of manslaughter caused by controlling or coercive behaviour. Existing law can already cover such circumstances.”

The United Kingdom Government

Specifically, the government argued that the common law of manslaughter already covers circumstances where death results from controlling or coercive behavior. Additionally, it pointed to section 2 of the Suicide Act 1961, which criminalizes encouragement or assistance of suicide. A specific offence, the government concluded, would not overcome the evidential difficulties of prosecuting these cases.

The petition closed in May 2024 with 17,849 signatures. Although it did not reach the 100,000 threshold required for a parliamentary debate, the campaign continued. Ms. Holland and Portsmouth City Councillor Kirsty Mellor pivoted to advocacy for a different route. Specifically, they sought an amendment to the Criminal Justice Bill that would have introduced a new clause in the House of Lords. The campaign continues to operate under the hashtag #HerNameWasChloeHolland.

The Wider UK Picture: Why This Legal Reform Matters

The scale of the problem has become impossible to ignore. In England and Wales, the National Police Chiefs’ Council’s Domestic Homicide Project tracks domestic abuse-related deaths.⁴ Home Office funding supports the project. Its data tells a clear story. For the second year running, suspected suicides following domestic abuse have outnumbered intimate partner homicides.

In the year ending March 2025, police recorded 347 domestic abuse-related deaths in England and Wales. Around 150 of these were suspected suicides following abuse. Across the five-year reporting period, the project has recorded over 1,400 such deaths in total. According to the NPCC, roughly three women die each week from suicide following domestic abuse.

Practitioners working with this population see why. The induced-suicidality configuration of coercive control is not rare. In many cases, it is the perpetrator’s stated goal. Perpetrators of coercive control often tell the people they victimize that they are worthless. They are told that their children would be better off without her. They are told “do it”. In my practice, I frequently hear accounts of victim-survivors who are told, “If I was that bad, you would have hung yourself,” or asked “Why didn’t you kill yourself?” Over time, the perpetrator’s voice becomes the victim’s internal voice. Eventually, the act follows. To understand this pattern in the context of broader narcissistic- and coercive abuse cycles, read about Trauma Bonding and Post-Separation Abuse.

The Research Evidence

The peer-reviewed evidence base supports the campaign. A 2022 study in SSM – Population Healthby Kafka and colleagues at the UNC Gillings School of Global Public Health analyzed National Violent Death Reporting System data.⁵ The researchers found that intimate partner violence is a precursor to roughly 6.1% of all suicides in the dataset. Notably, this figure is almost certainly an undercount. Detecting IPV as a contributing factor is difficult where the victim is no longer alive to describe what happened.

Additionally, research from a Kent and Medway suicide prevention program has suggested an even larger gap. Specifically, official statistics may capture only a small fraction of abuse-related suicides. Practitioners working in the field have long argued that the true scale of these deaths is far larger than the recorded numbers suggest.

To learn more, read Mica’s Law South Carolina: Coercive Control Bill Fails to Progress.

The Inquest Landmark: Kellie Sutton

In July 2023, an inquest jury at Cambridge and Peterborough Coroner’s Court returned a conclusion of “unlawful killing” in the case of Kellie Sutton. The conclusion marked a UK legal first. Specifically, it was the first time a jury had reached such a finding for a self-inflicted death following coercive and controlling behavior. Notably, the inquest established a principle. Coercive conduct can amount to the unlawful act required to support a manslaughter charge.

Kellie was 30 years old. She died in August 2017 following five months of severe coercive control and physical violence by her partner Steven Gane. The court convicted Gane of coercive and controlling behavior, assault occasioning actual bodily harm, and assault by beating. However, the CPS has never charged him with manslaughter. Her mother, Pam Taylor, continues to call for the Crown Prosecution Service to reconsider that decision. To read the full case study, see Kellie Sutton: Coercive Control, Suicide, and a UK Landmark.

The inquest conclusion is not a criminal conviction. Rather, it is a coroner’s finding on the balance of evidence about how someone died. Importantly, the principle the inquest established matters across the entire landscape of abuse-related death. Where coercive and controlling conduct can be shown to have caused a victim’s self-inflicted death, that death may amount to unlawful act manslaughter.

The Kiena Dawes Trial: A Painful Setback

On January 13, 2025, a jury at Preston Crown Court acquitted Ryan Wellings of the manslaughter of Kiena Dawes.⁶ Kiena was a 23-year-old hairdresser from Fleetwood, Lancashire. She took her own life on July 22, 2022. She left a note that read: “I was murdered.” In the note, she named Wellings as the man who had killed her.

The jury convicted Wellings of assault and coercive and controlling behavior. However, they did not find him guilty of manslaughter. The court sentenced him to six and a half years in prison. Later, he received an additional seven months for contempt of court after evidence emerged of witness coaching from prison.

The Wellings prosecution was only the third attempt by the CPS to bring a manslaughter charge in a case of this kind. The other two were Dhaliwal in 2006 and Allen in 2017. Of these three attempts, only Nicholas Allen has resulted in a conviction. He pleaded guilty in 2017 at Stafford Crown Court following the death of Justene Reece. Allen received ten years.

The Centre for Women’s Justice issued a sharp response to the Wellings verdict. Specifically, they argued that the defence had successfully exploited Kiena’s pre-existing mental health vulnerabilities to exculpate Wellings. This argument runs against well-established legal principle. Perpetrators must take their victims as they find them. This is the so-called “eggshell skull” rule. In the Centre’s analysis, the verdict demonstrated the urgent need for clearer jury direction. Ultimately, the case also reinforces the case for legal reform.

The Scottish Landmark: Lee Milne

On March 2, 2026, a jury at the High Court of Justiciary in Glasgow convicted Lee Milne of the culpable homicide of his wife Kimberly.⁷ The verdict marked a Scottish first. Specifically, it was the first time in Scotland that a court held an abusive partner criminally responsible for the death of a victim who took her own life. On April 10, 2026, Judge Lady Drummond sentenced Milne to eight years in prison.

Kimberly Milne was 28 when she died on July 27, 2023. She fell from a bridge over the A90 Kingsway West in Dundee and was struck by a vehicle. The court heard that in the hours before her death, Milne had driven erratically with her in the car, shouted at her, and grabbed hold of her. CCTV captured her terror. Witnesses described her as trapped against a wall.

Prosecutor Laura Buchan of the Crown Office and Procurator Fiscal Service told the court that Milne had “deliberately and ruthlessly exploited Kimberly’s vulnerabilities.” In sentencing, Lady Drummond said:

“By the jury’s verdict, you must bear responsibility not only for all of your abusive acts, but also for causing her death.”

Judge Lady Drummond

Scotland’s legal system is distinct from that of England and Wales.⁸ There, culpable homicide is the equivalent offence to manslaughter. Importantly, the Milne conviction is the first jury verdict in Britain to hold an abusive partner criminally responsible for a death by suicide arising from prolonged coercive control. It is a precedent. However, no equivalent precedent yet exists in England and Wales.

Where the Law Stands in 2026

The current legal landscape across the UK is shifting. Although the Holland petition did not result in a new statutory offence, several other developments have moved the position forward.

England and Wales

In June 2025, ministers announced that the law would be strengthened to recognize the link between domestic abuse and suicide.⁹ Specifically, the Domestic Homicide Reviews (DHRs) process is being renamed and expanded. It becomes the Domestic Abuse Related Death Reviews (DARDRs). The new framework explicitly includes suspected suicides where domestic abuse is suspected. The changes aim to improve investigations, capture more cases, and ultimately bring more perpetrators to justice.

Additionally, the Domestic Abuse Act 2021 already contains relevant provisions. Section 71 addresses encouragement of suicide in the context of domestic abuse. Section 2 of the Suicide Act 1961 also remains in force. Therefore, the legal scaffolding exists. What remains contested is its application.

Scotland

The Scottish Parliament has moved further than Westminster. On 7 October 2025, Holyrood passed the Criminal Justice Modernisation and Abusive Domestic Behaviour Reviews (Scotland) Bill unanimously. The Act creates a statutory framework for domestic homicide and domestic abuse-related suicide reviews. Implementation begins on 1 April 2026. Notably, the Act explicitly recognizes domestic abuse-related suicide as a category of fatal domestic abuse requiring systematic review.

Furthermore, the Milne conviction has established a precedent in Scottish criminal law. Practitioners and campaigners will watch closely to see whether further prosecutions follow.

The Wider Picture

England and Wales criminalized coercive control in December 2015 under section 76 of the Serious Crime Act. Scotland followed with the Domestic Abuse (Scotland) Act 2018. Many practitioners regard the Scottish Act as the strongest coercive control legislation in the world. Northern Ireland criminalized coercive control in 2022. Therefore, all four nations of the UK now recognize the offence. What remains uneven is whether the law recognizes the deadliest end of the coercive control spectrum: when the abuse drives the victim to her death.

What This Means for Survivors and Families

If you are a survivor reading this and recognizing the pattern, please know three things. First, the voice telling you that your life is not worth living is not your own. It is the perpetrator’s voice, internalized through sustained psychological abuse. Now it operates without the abuse perpetrator’s direct presence. Second, recovery from this depth of coercive trauma is hard but possible. Many survivors have done it. Third, you do not have to navigate this alone.

The platform offers a free 15-minute consultation as a starting point. Additionally, you can learn more about specialist support through narcissistic abuse recovery coaching. If you are in immediate distress in the UK, contact the Samaritans on 116 123 or the National Domestic Abuse Helpline on 0808 2000 247.

If you are a bereaved family member, the support of Action After Fatal Domestic Abuse (AAFDA)may help. AAFDA provides specialist peer support for families bereaved through domestic abuse. The charity has supported many of the families whose cases are referenced here.

What the Campaign Still Needs

Many years of direct practitioner work with survivors of severe and treatment-resistant coercive control confirm what bereaved families have been saying. Specifically, the induced-suicidality configuration of coercive abuse is real. It is patterned. It is recognizable. With the right legal architecture, it is also prosecutable.

The campaign now needs three things. First, sustained pressure on the CPS to bring more cases. One successful prosecution in England and Wales in nearly a decade does not reflect the rarity of the conduct. Rather, it reflects institutional reluctance. Second, training for police and prosecutors on how to investigate and frame these cases. Third, public recognition. What perpetrators do when they drive their partners to die is not a private tragedy. It is a crime.

To learn more about the broader legal landscape, read The Global Coercive Control Legislation Index, the platform’s flagship research resource. The Index tracks coercive control legislation worldwide. Peer-reviewed publications have cited the Index, including the Southern Illinois University Law Journal, Palgrave Macmillan, and the University of Agder.

Related Links

• The Complete Guide to Narcissistic Abuse Recovery
• The Cycle of Narcissistic Abuse: 4 Phases and the Mortal Discard
• Narcissist Smear Campaigns: What They Are and How to Survive
• Devaluation Phase: How Narcissistic Abuse Erodes the Self
• Kellie Sutton: Coercive Control, Suicide and a UK Landmark

Frequently Asked Questions

References

1. Hunter, M. (2023). Written evidence submitted to the Criminal Justice Bill Public Bill Committee (CJB06). Criminal Justice Bill. ↩︎
2. Seth, S., & Wapel, K. (2023, November 21). Chloe Holland death: Mum describes daughter’s coercive control battle. BBC News. ↩︎
3. HM Government. (2024, January 18). Response to petition: Create a statutory offence of manslaughter by coercive or controlling behaviour. ↩︎
4. National Police Chiefs’ Council. (2025). Domestic Homicide Project: Year five report. Home Office. ↩︎
5. Kafka, J. M., Moracco, K. E., Taheri, C., Young, B.-R., Graham, L. M., Macy, R. J., & Proescholdbell, S. (2022). Intimate partner violence victimization and perpetration as precursors to suicide. SSM – Population Health, 18, 101079. https://doi.org/10.1016/j.ssmph.2022.101079 ↩︎
6. Centre for Women’s Justice. (2025, January 14). CWJ response to the verdict in the trial of Ryan Wellings. ↩︎
7. Crown Office and Procurator Fiscal Service. (2026, April 10). Lee Milne sentenced for culpable homicide. Police Scotland. ↩︎
8. Scottish Parliament. (2025). Criminal Justice Modernisation and Abusive Domestic Behaviour Reviews (Scotland) Act 2025. ↩︎
9. Kafka et al. 2022. ↩︎