R v Franklin [1883] 9 QBD 360

Court: Court of Queen's Bench

Facts: D threw a wooden crate into the sea, which struck and killed V.

Held: The court found that the act was unlawful and dangerous, leading to a conviction for manslaughter. For constructive manslaughter there must be an unlawful act. The unlawful act must constitute a criminal offence. It is not sufficient that the act committed is against civil law.

Key Judicial Statement: Lord Coleridge CJ remarked, "The unlawful act must be one that is dangerous in the sense that a sober and reasonable person would recognize it as such."