“Defendant's failed poisoning attempt breaks causation chain despite victim's death”
White put potassium cyanide in his mother's drink intending to kill her and inherit under her will. His mother drank only a small amount and died shortly after from a heart attack. Medical evidence showed she died from the heart attack, not the poison.
Whether a defendant can be convicted of murder when their intended victim dies from a cause other than the defendant's act, and what constitutes sufficient causation in criminal law.
White could not be convicted of murder as his act did not cause his mother's death. He was convicted of attempted murder instead.
This case established the fundamental principle of factual causation in criminal law, requiring a clear causal connection between the defendant's act and the prohibited result. It remains a leading authority on causation in homicide cases.
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OSCOLA Citation
R v White [1910] 2 KB 124 (CCA)
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