Is it the norm for every case? For Milly Dowler there wasn't a known cause of death. Depends what they want to charge him with and how complicated the back story to that would be. Could homicide be falling into a river? I'd say that was suspicious in that he could argue against it. Unlikely tho that would be. I think it's homicide because she couldn't get herself into the river because she was already dead. How she was killed might be more difficult to ascertain.