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R v Church [1966]


  • The defendant believed that he had killed the victim through his assault during a fight stemming from her sexual-related insults
  • The victim actually drowned after the defendant disposed of the ‘body’ in a river


  • Did the defendant cause the death of the victim?


  • Yes


  • On the application of unlawful act manslaughter to the facts, there was no issue with the application of the coincidence doctrine
  • Test test for dangerousness in unlawful act manslaughter is an objective assessment of whether the defendant’s act might cause some harm
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