Regina v Church: CCA 1965

The defendant was convicted of manslaughter. After he had been unable to satisfy his female victim sexually, he had become angry and had seriously assaulted her. He mistakenly thought she was dead and tipped her in the river where she drowned.
Held: Edmund Davies J: ‘For such a verdict inexorably to follow, the unlawful act must be such as all sober and reasonable people would inevitably recognise must subject the other person to, at least, the risk of some harm resulting therefrom, albeit not serious harm.’


Edmund Davies J, NMarshall J, Widgery J


[1966] 1 QB 59, [1965] EWCA Crim 1, 129 JP 366, 49 Cr App Rep 206, [1965] 2 WLR 1220, [1965] 2 All ER 72



Cited by:

AppliedRegina v Goodfellow CACD 1986
The defendant had failed to get re-housed. He planned to burn down his present lodgings, rescuing the other inhabitants. Three died in his attempt. He appealed a conviction for manslaughter.
Held: The case was either an unlawful act or . .
CitedRegina v Coutts HL 19-Jul-2006
The defendant was convicted of murder. Evidence during the trial suggested a possibility of manslaughter, but neither the defence nor prosecution proposed the alternate verdict. The defendant now appealed saying that the judge had an independent . .
CitedAttorney-General’s Reference (No 3 of 1994) HL 24-Jul-1997
The defendant stabbed a pregnant woman. The child was born prematurely and died. The attack had been directed at the mother, and the proper offence was manslaughter.
Held: The only questions which need to be addressed are (1) whether the act . .
Lists of cited by and citing cases may be incomplete.


Updated: 08 June 2022; Ref: scu.191178