R v Mitchell [1983] QB 741

Court: Court of Appeal

Facts: D, frustrated while waiting in a post office queue, punched a man who then stumbled backward into an elderly woman, causing her to fall. The woman sustained injuries and subsequently died. D did not have any intent to harm the elderly woman directly but had aimed his aggression at the man he punched.

Held: The Court of Appeal upheld D’s conviction for manslaughter. The court applied the doctrine of transferred malice, ruling that D’s intent to harm the man transferred to the eventual victim, the elderly woman.

💡Levelup: The case reinforced the principle that D's liability remains the same, regardless of whether the harm is inflicted on the intended victim or another person, affirming the transfer of mens rea in cases of unintended victims.