R v Dawson [1985] 81 Cr App R 150

Court: Court of Appeal (Criminal Division)

Facts: D and accomplices committed a robbery, causing an attendant with a weak heart to suffer a fatal heart attack due to the stress of the situation.

Held: Appeal allowed. Conviction was quashed. The Court held that an unlawful act must be dangerous in the sense that it would be recognized as such by a reasonable person, not merely cause emotional shock.

Key Judicial Statement: Lord Lane CJ asserted, "An unlawful act must be assessed from the perspective of its capacity to cause physical harm, not just emotional distress."