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R v White [1910]


  • White added poison to a drink, intending to kill his mother
  • After drinking some of the drink, White’s mother died in her sleep of a heart attack, unconnected to the poison


  • Did White cause the death of his mother?


  • No


  • Factual causation and legal buy greenstone xanax causation are both required for a defendant to be said to have caused death
  • Recognition of a ‘but for’ test of factual causation
  • Irrespective of the poison, White’s mother would still have died
  • Today, White could still be convicted of attempted murder
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