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Facts

The deceased had asked the appellant for something that would make him sleep. The appellant then gave him a syringe to inject. After taking it, the deceased stopped breathing and was declared dead on reaching the hospital. The appellant was convicted for manslaughter and thus the appeal.

Issue

Whether the chain of causation breaks by the voluntary self-injecting act of the victim?

Rule

R v. Dalby: It was held that the supply of drugs in itself cannot be held to be a cause for death. R v. Dias: It was held that the causal link breaks if the victim had taken a  voluntary and well-informed decision of injecting the drug.

Analysis

The judges observed that the deceased had administered the drug himself, that it was a purely voluntary act. They further observed that it was not an act that was jointly performed by the deceased and the appellant. The Court also supported its stance with the help of Glanville Williams article which laid down the difference between mere accessories and perpetrators, and it is the perpetrator’s act that mattered.

Conclusion

It was held that the appellant did not in any way cause the victim to inject the drug on himself. The case highlights what would be considered a voluntary act breaking the causation chain.

Personal opinion

I agree with the decision of the Court. With reference to Glanville’s article, the appellant in this case was just an ‘accessory’ and not a ‘perpetrator’. He did not in any way force or convince the deceased to inject the drug. It was solely the decision of the deceased.

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