Constitutional law

A sovereign who died in office did not remain the embodiment of the state once deceased. The principle that a former head of state enjoyed only immunity ratione materiae applied to a late King as it applied to any head of state who stood down from office during his lifetime. Further, there was no justification for treating the estate of a head of state who died in office in a more favourable way than the living former head of state or the estate of such a former head of state who died some time after leaving office.