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R v Dhaliwal [2006]


  • The defendant had verbally abused his wife for many years
  • The wife committed suicide as a result of this abuse


  • Did the defendant cause his wife’s death?


  • No


  • Whilst mental harm by way of a recognised mental condition can be classed as harm, mere emotions are not enough to qualify
  • The defendant’s wife did not commit suicide as an immediate and reasonable response to the verbal abuse, but acted voluntarily
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