R v Thabo Meli [1954] 1 WLR 228

Court: Privy Council

Facts: D and his accomplices struck V on the head, intending to kill him. Believing V to be dead, they rolled his body off a cliff to dispose of it. V survived the initial head injury but later died from exposure after being left at the bottom of the cliff. The issue was whether D could be liable for murder when the final cause of death occurred after they had formed the intent to kill but believed V was already dead.

Held: The Privy Council upheld the murder conviction, ruling that the acts were part of a single transaction. The court reasoned that it was "impossible to divide up what was really one transaction." Even though V died from exposure, D’s initial intent and subsequent actions combined to form the requisite mens rea for murder.

💡Levelup: This case is crucial for the "one transaction" principle, where a series of acts can be considered as one for the purposes of establishing mens rea, even if the final cause of death was not directly caused by the initial act.