“Defendant liable for death caused by police response to his criminal actions”
Pagett held his pregnant girlfriend as a human shield while shooting at armed police officers who had come to arrest him. The police returned fire in self-defense, killing the girlfriend. Pagett was charged with manslaughter.
Whether a defendant can be held liable for manslaughter when the immediate cause of death was gunfire from police officers acting in self-defense in response to the defendant's actions.
The Court of Appeal upheld Pagett's conviction for manslaughter, finding that his actions were a substantial and operative cause of his girlfriend's death.
This case is fundamental to understanding causation in criminal law, particularly where intervening acts by third parties occur. It demonstrates that defendants remain liable when third parties act reasonably in response to the defendant's criminal conduct.
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OSCOLA Citation
R v Pagett (1983) 76 Cr App R 279 (CA)
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