Definition: In this task, you need to generate an appropriate title for the given summary of some paragraph. The generated title must be short and should include the main topic of the given text. Your summary should be less than 20 words long.
Input: A coroner is considering whether to refer Highways England to the Crown Prosecution Service (CPS) over the death of a woman on a smart motorway.

Coroner considers referring M1 smart motorway death to CPS