Facts
- Andrews injected insulin into the defendant, who died as a result
- This injection constituted a strict liability offence
Issue
- Could the act constitute unlawful act manslaughter?
Decision
- Yes
Reasoning
- 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
