Mr Atkins was tried and acquitted of the 20-year-old’s murder and manslaughter in 2009.
He did not give evidence at his own trial and police tapes of interviews with Mr Atkins were ruled as inadmissible evidence, as police at the time had not informed him he was a suspect.
It is still unknown what Mr Atkins knows about Mr Leveson’s death and whether he had any involvement.
Ms Truscott’s ruling forcing Mr Atkins to give evidence came with the caveat that any incriminating information he disclosed during the inquest could not be used against him in any hypothetical future criminal proceedings.
Mr Atkins was issued a certificate under section 61 of the NSW Coroner’s Act which granted him immunity from prosecution.
After five days of intense questioning at the inquest, Mr Atkins agreed to lead police to the body.
On Thursday, November 10, New South Wales police launched a search and started digging in Royal National Park south of Sydney, looking for the remains of Mr Leveson.
Can Michael Atkins face any charges?
At this stage it is very unlikely, because of three reasons — double jeopardy laws, the section 61 certificate he was issued by the NSW deputy coroner and a separate deal struck within the last week with NSW Attorney-General Gabrielle Upton.
Double jeopardy laws mean a person cannot be put on trial twice for the same offence, unless fresh or compelling new evidence is produced — a body for example.
Associate Professor Thalia Anthony from the University of Technology Sydney said the section 61 certificate issued by the coroner means he is free from prosecution from anything admitted during the coronial inquest, unless he lies or withholds evidence.
“According to the arrangement that has been made under section 61 of the coroner’s act, he is completely immune from any criminal prosecution arising from the evidence — including finding the body — that has occurred within the coronial inquest,” she said.
She said civil charges were also off the table.
“The Levesons have been very cooperative in the coronial jurisdiction and so they’ve sought to get to the bottom of the matter rather than pursue damages,” she said.