R v Andrew v DPP [1937] AC 576

Court: House of Lords

Facts: D, convicted of dangerous driving, caused V’s death. The offence was statutory but did not constitute a common law crime.

Issue : What standard of dangerous driving is required for the offence of manslaughter by dangerous driving?

Held: The House of Lords upheld the defendant’s conviction. The House of Lords ruled that dangerous driving, while a statutory offence, was not intrinsically criminal for the purposes of constructive manslaughter.

Key Judicial Statement: Lord Atkin noted, "To support a conviction for constructive manslaughter, the act must be a crime that is inherently dangerous, not merely a statutory crime involving carelessness."