R v Evans [2009] EWCA Crim 650

Court: Court of Appeal (Criminal Division)

Facts: D supplied heroin to her half-sister, V (aged 16), who overdosed. D did not seek medical help due to fear of prosecution.

Held: D was held liable for gross negligence manslaughter. The court ruled that D had created a life-threatening situation by supplying the drugs, which imposed a duty to act. Evans created such a situation by supplying heroin to her half-sister and failed to take further action to mitigate the danger she caused.

Key Judicial Statement: Lord Judge CJ emphasized, "If a defendant creates or contributes to the creation of a state of affairs which he knows, or ought reasonably to know, has become life-threatening, a consequent duty on him to act by taking reasonable steps to save the other's life will normally arise."