In Scotland, there has not been a single charge under the CMCHA 2007, never mind a conviction. However, in March 2023, Dorothy Bain KC, the lord advocate (the senior of two Scottish law officers), instructed the police to investigate whether the Scottish Prison Service should be prosecuted for corporate homicide — the Scottish equivalent of corporate manslaughter. This followed the death of remand prisoner Allan Marshall, who died after being restrained by 13 prison officers at HMP Edinburgh in 2015.