Criminal Law Summative

Word Count: 5036

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In English Law manslaughter consists of two categories: voluntary and involuntary. This essay
will cover only the second one. Involuntary manslaughter is a common law offence of unlawful
killing without the intention to kill or cause grievous bodily harm. 1 In the beginning there was
almost no distinction between unlawful act manslaughter and gross negligent manslaughter,
but Andrews v DPP made a clear distinction stated that negligent acts that were capable of
constituting stationary criminal offence could not qualify as unlawful act for unlawful act
manslaughter.2 Therefore, involuntary manslaughter in itself should be divided into unlawful
act manslaughter, manslaughter by gross negligence and reckless manslaughter. Unlawful act
manslaughter requires the death to occur as a result of a criminal act, which according to the
reasonable person was likely to result in some physical harm. The requirement of the level of
harm for gross negligent manslaughter is obvious risk of death. The category of reckless
manslaughter lacks clear definition on this matter but generally it is believed to be risk of
serious injury. These types of involuntary manslaughter require different degree of harm to be
foreseen. As this area of law is quite problematic it is impossible to provide a reasoned answer
which one should be used without looking at other requirements for each type of involuntary
manslaughter as they are balancing each other out. Also, this essay will look at the discretion in
sentencing available for the court in each of these types.

Unlawful Act Manslaughter

Unlawful act manslaughter is a constructive offence as it is built upon other criminal offences
and constructive liability. Lord Parker CJ described involuntary manslaughter as follows:
‘A man is guilty of involuntary manslaughter when he intends an unlawful act and one
likely to do harm to the person and death results which was neither foreseen nor
intended. It is the accident of death resulting which makes him guilty of manslaughter as
opposed to some lesser offence.’3
From this definition it can be concluded that the accused mens rea is of a based crime and is
assessed according to the unlawful act committed without any reference to the death that he
accidentally caused.
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1
Janet Loveless, Mischa Allen and Caroline Derry, Complete Criminal Law (6th edn, Oxford University Press 2018),
p 304
2
Andrews Appelant v Director of Public Prosecutions Respondent [1937] AC 576
3
R v Creamer [1966] 1 QB 72, at 82
As was stated above to be convicted of unlawful act manslaughter the defendant must have
caused death by committing unlawful act which was both unlawful and objectively likely to
result in some harm, not necessarily serious harm.4 Each of these elements has to be separately
proved but in practice they often overlap.

Unlawful Act

Due to the seriousness of the offence, since R v Franklin the main rule here is that unlawful act
should be a criminal not a civil one.5 Later cases supported the proposition that a mere
commission of tort will not be sufficient for unlawful act manslaughter. Sachs LJ in R v Lamb
stated that
‘…when using the phrase “unlawful in the criminal sense of the world’ the court has in
mind that it is long settled that it is not the point to consider whether an act is unlawful
merely from the angle of civil liabilities.’6
Moreover, Lamb has established that the prosecution should establishe a complete crime
which means both actus reus and mens rea have to be proved.7 In R v Lamb the prosecution
failed to establish that D had mens rea of the assault as he did not have intention or
recklessness to cause V to apprehend immediate unlawful force. 8

However, there are cases where this strict principle was significantly challenged. In DPP v
Newbury and Jones two boys were convicted of unlawful act manslaughter after accidentally
killing a train guard by throwing pavement stones over a railway bridge.9 That case is a great
example of the application of an objective test for dangerousness which would be discussed
later in the essay, but the House of Lords simply did not identify the based criminal unlawful
act.10 It was left unclear by the court that a complete criminal offence was required or given
effect of the facts only some criminal elements would suffice.11

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4
R v Church [1966] 1 QB 59
5
(1883) 15 Cox CC 1634
6
[1967] 2 QB 981, at 988
7
Ibid.
8
Ibid.
9
[1976] 2 All ER 365
10
Ibid,
11
Law Commission Consultation Paper No 135
Another step back from the principal can be found in R v Cato, the defendant has caused death
by injecting his friend, at his request, that happened to be a fatal quantity of heroin solution. 12
The defendant was convicted of unlawful act manslaughter based on the fact that he
committed a criminal offence contrary to section 23 of the Offences against the Person Act
1861 special attention should be brought to addition, obiter, made by Lord Widgery CJ:
‘…had it not been possible to rely on the charge under s 23 of the Offences against the
Person Act 1861, we think there would have been an unlawful act here, and we think
the unlawful act would be described as injecting the deceased Farmer with a mixture of
heroin and water which at the time of the injection and for the purpose of the injection
the accused had unlawfully taken into his possession.”13
Lord Widgery CJ argues that if the unlawful act has not been the s23 offence, there would be
another unlawful act of possession by the appellant. The problem is that the. Possession of a
drug is not a criminal offence and therefore cannot fulfil the requirement in R v Lamb.14

It can be argued that obiter dictum of Court of Appeal in this case and decision in DPP v
Newbury attempt to state that the unlawful act for involuntary manslaughter may not always
require to contain all the elements of a recognised criminal offence. That statements are
extremely controversial, as they significantly open the floodgate for the potential charges and
creates the possibility that a person can be charged with a serious criminal offence without
heaving mens rea of even lighter criminal offence.

Later cases have taken a more stringent approach towards the unlawful act. In R v Simon
Slingsby the court strike down conviction of an unlawful act manslaughter based on the crime
of battery as the defendant did not poses required mens rea because no injury was foreseen or
intended in a consensual sexual activity.15 In R v Dhaliwal the Court of Appeal declined to hold
the defendant liable for unlawful act manslaughter based on the s 20 Offences against Person
Act 1861 as there was no evidence of the psychological harm of required seriousness to be

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12
[1976] 1 WLR 110
13
Ibid, at 118
14
[1967] 2 QB 981; See requirement in n. 7
15
[1995] Crim LR 570
recognized as a psychiatric disorder.16 The overall consequences of lack of consistency in the
principle that in order to be convicted of unlawful act manslaughter all of the elements of the
base criminal offence should be established cannot and should not be evaluated without
reference to the dangerousness requirement and would be discussed later in the essay.

Dangerousness

Same as the requirement for a fully established base crime, the requirement that the unlawful
act must be dangerous was originally introduced to limit the ambit of unlawful act
manslaughter. The first requirement for the act to be dangerous was in R v Larkin, but it had
some problems not specifying was the test objective or subjective. 17

In R v Church Edmund Davies J covered that problem and introduced an objective test of
dangerousness stating that:
‘… the unlawful act must be such as all sober and reasonable people would inevitably
recognise must subject the other person to, at least, the risk of some harm resulting
therefrom, albeit not serious harm.’18
Although the conviction appeared to be based on gross negligence manslaughter, the case main
significance is for unlawful act manslaughter.

DPP v Newbury applied the objective test and stated that dangerousness need not to be
foreseen by the defendant.19 The question before the House of Lords was is it possible to
convict a person of a manslaughter even if the defendant did not foresee any harm for another,
Lord Salmon insisted that the test of dangerousness is an objective one and the question is
would all sober and reasonable people recognize the dangerousness of the act. 20 That raises the
moral problem of is it fair to make a person liable for the consequences that he had not
foreseen bearing in mind the level of harm that has to be foreseen is only some harm? In that
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16
[2006] EWCA Crim 1139, it should be noted that the lack of evidence was caused by the death itself as the victim
was never examined before death. The court also noted that if there was an unlawful physical violence on a fragile
and vulnerable personality the decision would be different.
17
[1943] 1 All ER 217, at 219
18
[1965] 2 All ER 72, at 70
19
[1976] 2 All ER 365
20
ibid
particular case that problem is even more significant as the defendant were convicted of such a
serious offence when House of Lords failed to identify any relevant unlawful act.

It can be argued that the doctrine behind the unlawful act manslaughter is that because the
defendant has committed a criminal act is fair just and reasonable for the court to make him
liable for any possible consequences of this crime. Essentially this doctrine developed in
relation to murder until Parliament had intervened in 1957.21 This doctrine in relation to
unlawful act manslaughter seems to be quite reasonable if all the recrements for the based
crime are fulfilled, however currently there is some inconsistency in that principle that is
discussed above that might lead to the idea that the serious harm should be foreseen by a
reasonable and sober man as it would level the lack of clarity for the base criminal offence.

The objective test was made slightly less harsh in R v Dawson, it was held that the reasonable
and sober man is of the same knowledge as the accused at the time of the offence, therefore if
any vulnerability of the victim was not obvious for the reasonable and sober man should be
ignored in the assessment of danger.22 That case restricted the applicability of the maxim of
‘thin skull rule’ in criminal law that the defendant must take their victims as they find them 23 in
relation to dangerousness in unlawful act manslaughter. This principle was confirmed in R v
Watson, in that case based on the facts robbery was not in itself dangerous until the V was
assaulted, but it should be noted that in that case the conviction failed due to lack of causation
as it was not proved that the burglary caused death.24 In the later case of R v Bristow it was
emphasized that the objective test of dangerousness is not related to the base offence itself but
mainly to the particular circumstances of the case. 25

I the vast majority of cases, unlawful act will be viewed dangerous as it raises an immediate risk
of some physical harm.26 However, since R v Ireland; R v Burstow serious psychological or
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21
Homicide Act 1957
22
[1985] CR APP R 150
23
R v Blaue [1975] 3 All ER; It should be noted that R v Dawson does not apply to the causation that the unlawful
act must cause death, ‘thin scull’ rule would still apply there.
24
[1989] 2 ALL ER 865
25
[2013] EWCA Crim 1540
26
Janet Loveless, Mischa Allen and Caroline Derry, Complete Criminal Law (6th edn, Oxford University Press 2018),
p 313
psychiatric injury that medically recognized can constitute actual or grievous bodily harm it
should be covered by this essay.27 The most significant type of such harm for the unlawful act
manslaughter is shock. R v Dawson stated that shock that was a result of fright is an injury to
the person, but it was added that the risk of shock needs to be obvious to the reasonable
man.28 R v Carey added that the shock has to be the cause of a physical harm leading to death
and a line of causation has to be established.29 In that case, if V had died from a physical shock
then manslaughter could have been left for the jury, but the facts showed that reasonable and
sober man would not have recognized danger of shock.

Both of those requirements in relation to shock makes it quite difficult for the defendant to be
convicted for unlawful act manslaughter if the shock in itself was something unpredictable as it
would be difficult to establish both that a reasonable man in position of the defender would
recognize danger of shock and chain of causation. Therefore, the requirement of some harm
instead of a serious one is reasonable and does not put the defendant in an extremely
vulnerable position as the danger of shock would not generally appear in the situations where it
is difficult to prove all the requirements of a base criminal act.

Manslaughter by gross negligence

The classic definition of gross negligence manslaughter was provided by Lord Herwart CJ in R v
Bateman:
‘If A has caused the death of B by alleged negligence, then, in order to establish civil
liability, the plaintiff must prove.. .that A owed a duty to B to take care, that that duty
was not discharged, and that the default caused the death of B. To convict A of
manslaughter, the prosecution must prove the three things above mentioned and must
satisfy the jury, in addition, that A's negligence amounted to a crime… in order to
establish criminal liability the facts must be such that, in the opinion of the jury, the
negligence of the accused went beyond a mere matter of compensation between

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27
[1997] UKHL 34
28
[1985] CR APP R 150
29
[2006] EWCA Crim 17
 subjects and showed such disregard for the life and safety of others as to amount to a
crime against the State and conduct deserving punishment’.30

This definition was uphold by House of Lords in Andrews v DPP31 and consists of the following
elements: (1) the defendant owed a duty to take care to the deceased, (2) the duty was
breached, (3) the death of the deceased was caused by the breach, (4) the breach was so gross,
that negligence of the defendant was so gross that it amounts to criminal rather than civil
liability.32 Later cases added another requirement that there is a need for the breach of the duty
to involve an obvious risk of death. Gross negligence manslaughter is significantly based on civil
law of tort, but not all tortious duties are applicable in criminal law.33

Duty of Care

In the law of manslaughter there is a serious lack of clear examination of duty of care in relation
to criminal liability. In criminal law duty of care is determined by the same principles as in civil
law of tort, however there are several significant differences that widen the scope of
applicability of the gross negligence manslaughter. This essay will not talk about obvious duties
of care such as in doctor-patient relationship and will focus on duties that expand the
applicability of the law of gross negligence manslaughter . One of the most criticized is a duty to
act which is determined by criminal law.34

R v Bateman case in attempt to provide formulation of gross negligence extended the

boundaries of it and introduced a duty to take care owned by the defendant to the deceased.35
In the first part of the classic definition of manslaughter Lord Hewart CJ by stating that the duty
is to ‘take care’ created situations where there is an obligation to act and. That created an
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30
(1925) 19 Cr App R 8
31
[1937] AC 576
32
That idea can also be found in Janet Loveless, Complete Criminal Law, 2018 at 293; Law Commission Consultation
Paper No 135, p. 36
33
See R v Khan and Khan [1998] Crim LR 830
34
Janet Loveless, Mischa Allen and Caroline Derry, Complete Criminal Law (6th edn, Oxford University Press 2018),
p 293
35
(1925) 19 Cr App R 8
offence of a gross negligent manslaughter committed by an omission. One of the most common
situations where omission is used as a ground for criminal liability under gross negligence
manslaughter is contractual relationship. Case of R v Pittwood considered a railway crossing
gatekeeper that opened the gate for the car to pass but forgot to close it and was charged with
gross negligence manslaughter for not closing it as it caused death. 36

Another area of law where there is a duty to act are cases where the defendant has caused a
dangerous situation for the deceased. Clear example of that is R v Gemma Evans where
defendant’s guilt arose from a failure to call for ambulance in full awareness of the risk to the
deceased.37 Same idea can be found in R v Bowler where the defendant was convicted of gross
negligence manslaughter after leaving the victim in danger created during sexual activity and
delaying to call emergency services due to panicking. 38

Duty to act under gross negligence manslaughter can occur after what can be called a voluntary
assumption of a duty to act. In R v Stone and Dobinson defendants were charged with gross
negligence manslaughter after breaching the duty to take care of a relative that lived in their
house.39 The court rejective the argument that presence of the diseased in the house did not
impose any obligation to act:

‘Whether Fanny was a lodger or not she was a blood relative of the appellant Stone; she
was occupying a room in his house; the appellant Dobinson had undertaken the duty of
trying to wash her, of taking such food to her as she required. There was ample
evidence that each appellant was aware of the poor condition she was in by mid-July...
All these were matters which the jury were entitled to take into account when
considering whether the necessary assumption of a duty to care for Fanny had been
proved...’40

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36
(1902) 19 TLR 37
37
[2009] EWCA Crim 650
38
[2015] EWCA Crim 849
39
[1977] 1 QB 354
40
Ibid, at 361
In this case the court decided that actions that the defendants essentially performed were
enough to prove that they have voluntary assume duty to take care and breached it by not
calling ambulance or police in order to help the diseased.

R v Winter and Winter clearly stated that the duty of care must be objectively foreseeable,
therefore, it does not matter if the defender had foreseen that duty. 41 Hooper LJ stated:
‘In our view it is reasonable foreseeable that civilian employees of the fire service in the
position of Mr Wembridge may come on to and close to the site of a fire in order to film
or photograph it…Does that duty cease to be owed because Mr Wembridge may have
disobeyed instructions? Counsel for the applicants conceded that they could show us no
authority to suggest that a failure to comply with instructions resulted in there being no
duty owed. Such a failure may be relevant on the issue of causation and, in civil cases, to
the issue of causation, volenti and contributory negligence. It is not arguable, in our
view, that any failure to comply with instructions in this case had the consequence that
no duty of care was owed to Mr Wembridge. To whom such a duty extends must
depend upon all of the facts of the individual case.’42
That puts the defendant in a more vulnerable position, however, that case also stated that the
reasonable foreseeability should be decided upon all facts of the individual case including the
actions of the victim. That case is quite complicated in judgement. It is true that the court
stated that duty of care and causation are different concepts and contributory negligence of the
victim did not cease the duty, however, it is not clear should the fact that victim ignored the
instructions was one of the facts to be considered by the jury while deciding was there a duty of
care or not.

Finally, it is not that clear who should establish a duty of care to exist. In R v Singh it was held by
the Court of Appeal that it is for the judge to decide is there a duty of care or not. 43 Later in R v
Willoughby it was held that the judge should decide is the evidence is sufficient enough to
establish the duty and the existence of it is a question for the jury. 44 That judgement created
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41
[2010] EWCA Crim 1474
42
Ibid, at 22-25
43
[1999] Crim LR 582
44
[2004] EWCA Crim 3365
the problem that a matter of law rather than of facts was left for the jury which is potentially is
against Article 6 and Article 7 of the ECHR.45 That issue was dealt with in R v Gemma Evans with
Lord Judge LCJ attempting to clarify the law:
‘In any cases where the issue is in dispute, and therefore in more complex cases, and
assuming that the judge has found that it would be open to the jury to find that there
was a duty of care, or a duty to act, the jury should be directed that if facts a + b and/or
c or d are established, then in law a duty will arise, but if facts x or y or z were present,
the duty would be negatived. In this sense, of course, the jury is deciding whether the
duty situation has been established. In our judgment this is the way in which Willoughby
should be understood and, understood in this way, no potential problems arising
from article 6 and article 7 of the ECHR are engaged.’46
This judgment seems to take a step back to R v Singh rather than clarifying R v Willoughby as it
clearly states that the jury deals with the mater of facts, however the real difference between
the ‘deciding whether the duty situation is established’ and deciding is there a duty or not is a
vague one. It can be argued that under the current law the decision is there a duty of care or
not is for the judge, and his decision should depend on the facts found by the jury.

Breach of Duty

In establishing has the defendant breached the duty normal rules of civil law of tors apply in
gross negligent manslaughter. The main difference is that the breach should impose a risk of
harm. In R v Stone and Dobinson requirement was set at risk of serious harm.47 Later, due to the
fact that duty can be breached in a variety of ways both lawfully and unlawfully and also by
omission in R v Adomaco Lord Mackay LC limited the scope of gross negligence manslaughter
by stating:
‘On this basis in my opinion the ordinary principles of the law of negligence apply to
ascertain whether or not the defendant has been in breach of a duty of care towards the
victim who has died. If such breach of duty is established the next question is whether
that breach of duty caused the death of the victim. If so, the jury must go on to
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45
Janet Loveless, Mischa Allen and Caroline Derry, Complete Criminal Law (6th edn, Oxford University Press 2018),
p 293
46
[2009] EWCA Crim 650, at 45
47
[1977] 1 QB 354
 consider whether that breach of duty should be characterised as gross negligence and
therefore as a crime. This will depend on the seriousness of the breach of duty
committed by the defendant in all the circumstances in which the defendant was placed
when it occurred. The jury will have to consider whether the extent to which the
defendant's conduct departed from the proper standard of care incumbent upon him,
involving as it must have done a risk of death to the patient, was such that it should be
judged criminal.’48
The requirement of a risk of death was later qualified to be an objective one stating that ‘the
circumstances must be such that a reasonably prudent person would have foreseen a serious
and obvious risk not merely of injury, even serious injury, but of death.’49 The objectivity and
requirement for obvious risk of death significantly limit the scope of the law making it much
more balanced

R v Adomako is also significant in outlining the requirement for the breach to be serious enough
to be a crime.50 The test in R v Adomako is heavily criticised for circularity and lack of clarity as it
was not defined in the case. Also, due to the circularity it can be argued the jury is answering
the question of law. According to the test defendant’s negligence is criminal if it is gross, and it
is gross if it is so bad it is a crime. Another problem with that requirement, is that it overlaps
with the one discussed before, as if the breach was of and obvious risk of death, it would
probably be classified by the jury as gross negligent and therefore probably would be regarded
as criminal.

In order to summarise argument, this essay states that gross negligent manslaughter
significantly lacks the required mens rea that should be required in such serious offence as
manslaughter.

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Reckless Manslaughter

48
[1994] 3 WLR 288, at 18; That quote is also related to the requirement for the jury to decide was the breach
serious enough to be a crime that will be dealt later in the essay
49
[2004] EWCA Crim 2375 LJ Judge at 49; R v Mark [2004] EWCA Crim 2490 clarified that knowledge or
foreseeability of the risk by the defendant is irrelevant and the test is objective one.
50
See n 49
As was stated in the introduction this category of manslaughter lacks secure definition. The
main reason for that is that ‘reclessnes’ developed under gross negligence manslaughter and
often was used interchangeably with term ‘gross negligence’. One of the most recent cases that
attempted to provide explanation in the area is R v Lindar.51 In that case Evans LJ clearly stated
that under the law of the time nothing suggested that ‘recklessness’ could no longer be a basis
for proving the offence of manslaughter.52 It was stated that (1) there should be high probability
of physical harm, (2) the risk is of a serious injury rather than ‘injury to heath’ or ‘some physical
harm’, (3) the fact that the jury also established the fact that harm was foreseen by the
defendant, may be argued to be the third requirement that the defendant should be aware of
risk of serious harm.53 Therefore, reckless manslaughter may be assumed to have a more
limited mens rea than gross negligent manslaughter.

Sentencing Discretion

Before this essay would finally summarise which level of harm should be foreseen in
involuntary manslaughter a brief outline of sentencing should be done. There are three possible
consequences (1) a prison sentence ranging from 2 years to life sentence, (2) a suspended term
of imprisonment, (3) community service.54 However, in practice, the possibility of being
sentenced to life imprisonment is relatively low. In 2014 out of 107 offenders sentenced for
unlawful act manslaughter only two were sentenced with life imprisonment, one was subject to
a hospital order and the remainder were sentenced to determinate custodial terms ranging
from 2 to 24 years.55 For gross negligent manslaughter in 2014 all of the 16 offenders were
sentenced to determinate custodial terms ranging from nine months to 12 years. 56

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Conclusion

51
[2000] 4 Archbold News 3
52
Ibid.
53
Ibid.
54
Sentencing Council Consultation Manslaughter Guideline, 2017
55
Ibid.
56
Ibid.
The general maxim that explains difference in required foresight of harm can be found in
statement of Lord Atkin in Andrews v DPP that ‘there is an obvious difference in the law of
manslaughter between doing an unlawful act and doing a lawful act with a degree of
carelessness which the Legislature makes criminal’.57 Argument of Lord Atkin provides a clear
and logical explanation that if manslaughter was committed during and unlawful act the
defendant should be liable for much broader consequences. At the same time it is not morally
justified to make people to responsible for the consequences of there legal actions that were
performed in a way that caused criminal liability to the same level as people from the beginning
acting illegally in criminal sense and who’s actions caused death. Therefore, it should be argued
that is impossible to have the same foresight of harm for all in voluntary manslaughter and it
should not be done.

Another problem with the current law is irrelevance towards defender’s culpability to
appreciate or be aware of the risk as it is difficult to morally justify conviction of a person for
actions consequences of which that person did not understand and that does not has a ‘guilty
mind’. That issue was covered by the Law Commission Proposal. 58 The proposal is to combine
reckless manslaughter and gross negligence manslaughter into ‘killing by gross negligence’
manslaughter with four requirements: (1) defendant causes the death of the victim, (2) the risk
of causing death is obvious to a reasonable person in position of the defendant, (3) defendant
should be capable of appreciating that risk, (4) the conduct if the defendant falls significantly
below risk that can be expected of him or her in the circumstances of the case. 59 This proposal
simplifies the law as it put the requirements of risk for reckless and gross negligence
manslaughter and introduces so needed requirement of a ‘guilty mind’. For unlawful act
manslaughter the significant change proposed involves introduction of a ‘guilty mind’ by
requiring intention to cause injury or awareness by the defendant of a serious risk of causing
some injury.60 The subjectivity of the test significantly limits the applicability of such serious
offence and makes majority of the convictions easily morally justifiable. This essay would
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conclude, that the foresight of harm should be the same as the one proposed by the
Commission.

57
[1937] AC 576, at 585
58
Law Commission Consultation Paper No 304
59
Ibid.
60
Ibid.
Bibliography:
Cases
Andrews Appelant v Director of Public Prosecutions Respondent [1937] AC 576
DPP v Newbury [1976] 2 All ER 365
R v Adomaco [1994] 3 WLR 288
R v Bateman (1925) 19 Cr App R 8
R v Blaue [1975] 3 All ER
R v Bowler [2015] EWCA Crim 849
R v Bristow [2013] EWCA Crim 1540
R v Burstow [1997] UKHL 34
R v Cato [1976] 1 WLR 110
R v Carey [2006] EWCA Crim 17
R v Church [1966] 1 QB 59
R v Creamer [1966] 1 QB 72
R v Dawson [1985] CR APP R 150
R v Dhaliwal [2006] EWCA Crim 1139
R v Franklin (1883) 15 Cox CC 1634
R v Gemma Evans [2009] EWCA Crim 650
R v Ireland [1997] UKHL 34
R v Khan and Khan [1998] Crim LR 830
R v Lamb [1967] 2 QB 981
R v Larkin [1943] 1 All ER 217
R v Lindar [2000] 4 Archbold News 3
R v Pittwood (1902) 19 TLR 37
R v Simon Slingsby [1995] Crim LR 570
R v Singh [1999] Crim LR 582
R v Stone and Dobinson [1977] 1 QB 354
R v Watson [1989] 2 ALL ER 865
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R v Willoughby [2004] EWCA Crim 3365
R v Winter and Winter [2010] EWCA Crim 1474
Legislations
Homicide Act 1957

Consultation Papers
The Law Commission Consultation Paper No 135, Involuntary Manslaughter, 1994
The Law Commission Consultation Paper No 304, Murder, Manslaughter and Infanticide, 2006

Articles
Storey T, 'Unlawful And Dangerous: A Comparative Analysis Of Unlawful Act Manslaughter In
English, Australian And Canadian Law' [2017] Journal of Criminal Law.
Leigh G, 'Deconstructing Unlawful Act Manslaughter' [2017] Journal of Criminal Law.

Books
Janet Loveless, Mischa Allen and Caroline Derry, Complete Criminal Law (6th edn, Oxford
University Press 2018).