“Drug supplier liable for manslaughter after failing to summon help”
Evans supplied heroin to her half-sister and another person. When her half-sister collapsed from an overdose, Evans failed to call emergency services or seek medical help, instead removing evidence of drug use. The half-sister died from the overdose.
Whether a person who creates or contributes to a life-threatening situation can be liable for gross negligence manslaughter based on their subsequent failure to act
The Court of Appeal upheld Evans' conviction for gross negligence manslaughter, ruling that liability can arise where a defendant creates or contributes to a dangerous situation and then fails to take reasonable steps to counteract the danger
This case significantly expanded the circumstances in which omissions can ground criminal liability, establishing a new category of duty situations in gross negligence manslaughter.
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OSCOLA Citation
R v Evans [2009] EWCA Crim 650, [2009] 1 WLR 1999
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