Lord Lane CJ said: ‘It seems to us that where the unlawful application of force and the eventual act causing death are parts of the same sequence of events, the same transaction, the fact that there is an appreciable interval of time between the two does not serve to exonerate the defendant from liability. That is certainly so where the appellant’s subsequent actions which caused death, after the initial unlawful blow, a designed to conceal his commission of the original unlawful assault.
It would be possible to express the problem as one of causation. The original unlawful blow to the chin was a causa sine qua non of the later actus reus. It was the opening event in a series which was to culminate in death: the first link in the chain of causation, to use another metaphor. It cannot be said that the actions of the appellant in dragging the victim away with the intention of evading liability broke the chain which linked the initial blow with the death.’
Lord Lane CJ
[1991] 4 All ER 673, [1992] QB 61, [1991] 3 WLR 653
England and Wales
Crime
Leading Case
Updated: 02 November 2021; Ref: scu.550150