R v Watson [1989] 1 WLR 1207

Court: Court of Appeal (Criminal Division)

Facts: D burgled V’s home, who had a heart condition. V suffered a fatal heart attack as a result of the burglary.

Held: Conviction for manslaughter upheld. The court ruled that the burglary was dangerous given the circumstances, even though V’s heart condition was not known to D. The act of burglary does not end when D crosses the threshold of the premises. A sober and reasonable person would have recognised V’s vulnerability at once.

Key Judicial Statement: Lord Lane CJ stated, "Dangerousness must be assessed in the context of the unlawful act and the circumstances, including the victim’s known vulnerabilities."