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R v Carey [2006]


  • The victim was threatened by some gang members, and ran away
  • During the running away, the victim suffered a fatal heart attack


  • Were the gang members guilty of unlawful act manslaughter?


  • No


  • The threats were not unlawful
  • The victim was not escaping, merely exiting at speed, not as a result of the threats
  • The threats therefore did not cause the victim’s death
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