R v Smith [1959] 2 QB 35

Court of Appeal (Criminal Division)

Facts: D stabbed another soldier who was mishandled on the way to medical help, potentially worsening his condition.

Issue : Could the negligence of the medical professionals break the chain of causation between D’s act of stabbing the victim and the victim’s death?

Held: The original wound was still an "operating and substantial cause" of death, establishing causation. The court clarified that to break the chain of causation, the intervening act must be an unwarranted, new cause that disrupts the sequence of events and is unreasonable, extraneous, or extrinsic.

Key Judicial Statement: Lord Parker CJ stated, "The wound inflicted was still a substantial cause of death unless a subsequent cause was so overwhelming as to make the original wound part of history."

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R v Clinton [2012] EWCA Crim 2

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R v Miller [1983] 2 AC 161