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R v Andrews [2002]


  • Andrews injected insulin into the defendant, who died as a result
  • This injection constituted a strict liability offence


  • Could the act constitute unlawful act manslaughter?


  • Yes


  • An ‘unlawful act’ for the purposes of unlawful act manslaughter may be a strict liability offence (even if regulatory/administrative in nature)
  • In accordance with previous cases, particularly Andrews v DPP [1937], and unlawful act does not include torts; the act must be a crime
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