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R v Dhaliwal [2006]

Facts

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

Issue

  • Did the defendant cause his wife’s death?

Decision

  • No

Reasoning

  • 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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