For the families of the missing, justice is often a hollow word when there is no grave to visit. In Scotland, a significant legislative shift has finally addressed the psychological torment of "no body" murders. As of March 26, 2026, the Scottish legal system has formally integrated Suzanne’s Law into its parole processes. This change, part of the wider Victims, Witnesses, and Justice Reform Act, ensures that the refusal of a killer to disclose the location of their victim's remains is a primary factor in determining their suitability for release. It is a moment of sombre victory for campaigners who have spent decades arguing that a prisoner who keeps such a secret has not been truly rehabilitated.
The law takes its name from Suzanne Pilley, an Edinburgh bookkeeper who vanished on her way to work in May 2010. Her killer, David Gilroy, was convicted of her murder despite her body never being found. For sixteen years, Gilroy has maintained a wall of silence, leaving Suzanne’s family in a state of perpetual limbo. The introduction of this law means that the Parole Board for Scotland must now explicitly consider whether a prisoner is withholding information about the disposal of remains. It essentially creates a scenario where silence acts as a barrier to freedom, forcing perpetrators to choose between their secrets and their liberty.
The push for this legislation was not just about Suzanne Pilley. It was fueled by the collective grief of multiple families, including that of Arlene Fraser, who disappeared from her home in Elgin in 1998. Her husband, Nat Fraser, was eventually convicted of her murder, but her remains have never been recovered. For these families, the "no body, no parole" rule is not about vengeance; it is about the fundamental right to a proper burial and the closure that only comes when the final chapter of a tragedy is written.
The harrowing cases that forced a change in Scottish law
To understand why Suzanne’s Law is so vital, one must look at the specific cases that highlighted the gaps in the previous system. Suzanne Pilley was 38 when she disappeared. She was last seen on CCTV entering her office building in Thistle Street, Edinburgh, but she never made it to her desk. The subsequent investigation into her colleague and former lover, David Gilroy, painted a picture of a man who could not accept the end of their relationship. Gilroy was seen with scratches on his face and hands shortly after she went missing. He made a suspicious trip to Argyll, and his car’s odometer showed an extra 124 miles that he couldn't explain. Despite a mountain of circumstantial evidence leading to his conviction in 2012, he has never uttered a word regarding where he hid Suzanne’s body.
The case of Arlene Fraser is equally chilling and served as a catalyst for the Scottish Liberal Democrats to push for reform. Arlene was a mother of two who vanished after dropping her children at school. The case became one of the most famous in Scottish legal history, involving two trials for her husband, Nat Fraser. A key piece of evidence was Arlene’s wedding rings, which mysteriously appeared in her bathroom nine days after she disappeared: rings she had been wearing when last seen. The prosecution argued Nat had arranged for her to be killed and her body disposed of. Like Gilroy, Nat Fraser has remained silent for over a quarter of a century.
These cases exposed a cruel reality: a murderer could serve their minimum tariff and apply for parole while still exerting total control over the victim’s family by withholding the location of the body. Before this law, the Parole Board could consider a lack of remorse, but there was no statutory requirement to specifically weigh the non-disclosure of remains. This allowed killers to maintain a final, lingering act of domestic or personal abuse from behind bars. The new legislation aims to strip that power away, making the "no body" status a significant weight in the scales of justice.
How the new parole framework operates in practice
The implementation of Suzanne’s Law does not mean an automatic, blanket ban on parole for all "no body" killers, but it makes the hurdle for release significantly higher. Under the new guidelines, the Parole Board for Scotland is legally mandated to take into account whether a prisoner has information about the location of a victim’s remains and has failed to disclose it. This is not just a box-ticking exercise; it is a fundamental assessment of the prisoner’s level of cooperation and, by extension, their rehabilitation. The logic is simple: a prisoner cannot be considered safe or reformed if they continue to inflict psychological harm on the victim’s family by withholding the truth.
The process begins when a prisoner becomes eligible for parole at the end of their court-mandated punishment part of their life sentence. During the hearing, the board will review all available evidence, including police reports and judicial summaries, to determine if it is likely the prisoner knows where the remains are. If the board finds that the prisoner is intentionally remaining silent, this will be recorded as a major factor against their release. The burden of proof effectively shifts toward the prisoner needing to demonstrate why they should be released while still maintaining their silence on such a critical issue.
Justice Secretary Angela Constance has been vocal about the importance of this shift, stating that the inability to bury a loved one compounds the trauma of the initial crime. The law was introduced as an amendment by MSP Jamie Greene, who worked closely with the affected families to ensure the wording was robust. It reflects a growing trend in UK law: similar to "Helen’s Law" in England and Wales, named after Helen McCourt: that prioritises the rights of victims and their families over the convenience of the perpetrator. For the Parole Board, this provides a clearer mandate to keep dangerous and unrepentant individuals incarcerated until they show a genuine desire to mitigate the ongoing suffering they have caused.
The psychological impact and the search for closure
For the families involved, the passage of Suzanne’s Law is the culmination of years of campaigning and emotional exhaustion. The concept of "ambiguous loss" is well-documented in forensic psychology; it is a form of grief that has no resolution because the person remains missing. Unlike a death where a body is recovered and a funeral is held, a "no body" murder keeps the family in a permanent state of high-alert and trauma. They are denied the physical evidence of death, which often leads to a fractured mourning process and a life lived in the shadow of "what if."
The law is a recognition by the Scottish Parliament that the state has a duty to help resolve this ambiguity. By putting pressure on killers to speak, the legal system is finally acknowledging that the harm of a murder does not end with the act of killing. It continues every day the body remains unfound. For Suzanne Pilley’s parents, the hope is that as David Gilroy ages and faces the prospect of never seeing the outside world again, the incentive to finally reveal the truth will become too great to ignore. Even if the remains are never found due to the passage of time or environmental factors, the act of attempting to cooperate is seen as a necessary step toward some form of redemption.
This legislative change also serves as a deterrent and a statement of societal values. It sends a message to future offenders that the "perfect crime": one where the body is never found: will not lead to a shorter path to freedom. Instead, it will lead to a much longer stay in the prison system. While no law can bring back those who have been lost, Suzanne’s Law ensures that the silence of the guilty is no longer rewarded by the system. As the first parole hearings under these new rules begin to take place in late 2026, the eyes of the nation will be on the Parole Board to see how strictly these measures are enforced. For the families of the missing, it is a long-overdue step toward a justice that finally sees their pain.
