What is the ratio in R v Blaue?

The ratio is that the thin skull rule applies to religious beliefs and moral convictions as well as physical characteristics. A defendant must take their victim as they find them, including their religious beliefs.

What did the court decide in R v Blaue?

The Court of Appeal held that the victim's refusal of a blood transfusion on religious grounds did not break the chain of causation, and the defendant was properly convicted of manslaughter.

Why is R v Blaue important for criminal law?

It extends the thin skull rule beyond physical characteristics to include religious beliefs, establishing that defendants are responsible for consequences flowing from their victim's reasonable religious convictions.

What is the ratio in R v Blaue?

The ratio is that the thin skull rule applies to religious beliefs and moral convictions as well as physical characteristics. A defendant must take their victim as they find them, including their religious beliefs.

What did the court decide in R v Blaue?

The Court of Appeal held that the victim's refusal of a blood transfusion on religious grounds did not break the chain of causation, and the defendant was properly convicted of manslaughter.

Why is R v Blaue important for criminal law?

It extends the thin skull rule beyond physical characteristics to include religious beliefs, establishing that defendants are responsible for consequences flowing from their victim's reasonable religious convictions.

Criminal1 min read

R v Blaue

[1975] 1 WLR 1411Court of Appeal1975

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“You must take your victim as you find them, including religious beliefs.”

Facts

Blaue stabbed a young Jehovah's Witness who refused a blood transfusion on religious grounds and died as a result. Blaue argued that her refusal to accept medical treatment broke the chain of causation.

Issues

Whether a victim's refusal of medical treatment on religious grounds breaks the chain of causation between the defendant's act and the victim's death.

Held

The Court of Appeal dismissed the appeal. The victim's religious beliefs were part of her makeup and the defendant had to take his victim as he found her.

Significance

This case firmly established that the thin skull rule extends beyond physical characteristics to include religious and moral beliefs. It's fundamental to understanding causation in criminal law and the extent of a defendant's responsibility for consequences.

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OSCOLA Citation

R v Blaue [1975] 1 WLR 1411 (CA)

Criminal LawCausationThin Skull RuleReligious BeliefsHomicide

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