“Hidden vulnerabilities don't make unlawful act dangerous if unforeseeable to reasonable person”
Three defendants attempted to rob a petrol station. The 60-year-old attendant appeared physically fit but had serious heart disease unknown to the defendants. He suffered a fatal heart attack during the robbery attempt. There was no violence or threats beyond the inherent intimidation of the robbery.
Whether the defendants could be liable for unlawful act manslaughter when the victim's death resulted from a pre-existing heart condition that was not apparent to a reasonable observer.
The Court of Appeal quashed the manslaughter convictions. The unlawful act was not dangerous because a reasonable person would not have foreseen risk of harm to someone who appeared physically normal.
This case establishes crucial limits on liability for unlawful act manslaughter, protecting defendants from liability for truly unforeseeable consequences. It demonstrates the importance of the objective foreseeability test and is essential for understanding when defendants can and cannot be held liable.
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OSCOLA Citation
R v Dawson (1985) 81 Cr App R 150
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