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A-G Reference (No. 4 of 1980) [1981]


  • The defendant pushed his girlfriend down a staircase before cutting her throat and then dismembering her body
  • It was impossible to prove which of the acts caused the death of the defendant’s girlfriend


  • Was the defendant guilty of manslaughter?


  • Yes


  • As long as the necessary mens rea was present throughout the acts, a manslaughter conviction could follow, irrespective of the coincidence principle
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