R v Goodfellow [1986]

Court: Court of Appeal

Facts: The appellant, Goodfellow, faced charges of arson and manslaughter after setting fire to his own house to simulate a petrol bomb attack. He intended this act to force a relocation due to conflicts with his neighbors. Unfortunately, the fire led to the deaths of his wife, his son, and his son's girlfriend.

Issue: Could Goodfellow be convicted of manslaughter if his unlawful act, though not directly targeting the victims, posed a foreseeable risk of harm, and if all reasonable people would have recognized this risk?

Held: The appeal was dismissed, and the convictions were upheld. The Court of Appeal confirmed that Goodfellow’s actions created a recognizable risk of harm, sufficient for an unlawful and dangerous act manslaughter conviction.

Key Judicial Statements: The court clarified that the unlawful act must pose a risk that sober and reasonable people would recognize. The act does not need to be directly aimed at the victim, and the "unlawful and dangerous act" manslaughter conviction applies if the act inherently poses a risk of harm to others.

💡 Leveluplaw: This case emphasizes that in unlawful act manslaughter, the defendant’s actions do not need to be aimed directly at the victims. As long as the act creates a foreseeable risk of harm to another person, the defendant can be held liable for the resulting deaths, reinforcing accountability for reckless behavior leading to unintended fatalities.