The appellant, on being refused sexual intercourse by the victim, stabbed her with a knife. When she reached the hospital, the doctors mentioned that she would have to get a blood transfusion to survive. Since the victim was a Jehovah’s Witness, she refused blood transfusion as it was against her beliefs. As a result, she died.
Whether the chain of causation between the appellants act and the end result was broken by the intervening act of the victim?
R v. Holland: It was held that one who causes injury which results in death cannot claim innocence by saying that death would not have occurred if better care was taken by the victim. In R v. Smith it was held that if the wound inflicted by the appellant was still operating and substantial, the chain of causation will not break.
The Court upheld the rule that the victim must be taken as they are. They further elaborated on this by saying that the victim is not just the physical victim, but also a person with beliefs important to their way of life. Ultimately, it was the stab wound that caused the death and the victim choosing not to undergo blood transfusion did not break the causal chain.
The appellants appeal failed and was convicted. The case gives an idea as to which intervening voluntary acts actually break the causal chain.
In my opinion, if someone intentionally causes injury to a vital part of the body such as the chest, the accused cannot blame the victim if the victim has certain religious and moral beliefs or even physical disabilities. Thus, I agree with the judgement.